We can win this campaign – County Durham SHMA rejected because of too many houses

We Love Hart Campaign Logo

We Love Hart Campaign Logo

A recent highly critical interim report from the inspector of County Durham’s local plan demonstrates we can win the We Heart Hart campaign against Hart District Council’s Local Plan.

The Durham report has a number of interesting points:

  • The Objectively Assessed Need (OAHN) has been found too high because it was based on unrealistic jobs growth and inward migration assumptions.  This finding is relevant to Hart District, Hampshire because our Strategic Housing Market Assessment (SHMA) relies upon inward migration numbers from the time we were building the most and on jobs growth assumptions that are nearly double those achieved in the boom times of 1998-2008.
  • County Durham carried out a very extensive consultation process, but they were criticised for demonstrating “little evidence of willingness to respond positively to contrary views or to simplify the process to encourage genuine public engagement”.  It seems that despite having a wide ranging consultation process, the Local Plan failed.  Given that Hart is carrying out less consultation than Durham, even less than it originally said it would, and seems impervious to suggestions of focusing more strongly on brownfield sites, then this would seem to be a significant risk to the current Hart District Local Plan.
  • Finally one consultee  said “that a comparison should have been made with alternatives such as a ‘moderate growth’ alternative accommodated on brownfield sites….The Council has dismissed such an alternative which seems to me to have significantly diminished the credibility of the SA”.  Again the significance for Hart is obvious in that Hart has refused to consider seriously an alternative solution of building higher density developments on the many vacant brownfield sites in the district.

If you would like to join our campaign to get Hart to think again, then please sign and share our petition:

 

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Fleet and Church Crookham to be devastated by congestion from new town

Estimated Extra Daily Journeys

Extra Daily Journeys

5,000 extra houses in a new town in Hart District will dramatically increase congestion all over the district, including Fleet and Church Crookham with 10’s of thousands of extra journeys per day.   It is clear that those councillors who think they are getting a free-ride from a new town in Winchfield need to think again and campaign for fewer houses to be built overall.

If you think the council should think again, please sign the petition: https://you.38degrees.org.uk/petitions/we-hart

Hart District Council have been asked by Winchfield Action Group (WAG), as part of their Neighbourhood Planning process to provide some figures on the current road usage on roads in and around the proposed new town at Winchfield and for an assessment of the impact on neighbouring areas.  Astonishingly, it seems Hart doesn’t have any traffic monitoring data.

Helpfully, the appendices in the Strategic Housing Market Assessment (SHMA) give an analysis of the travel to work patterns of Hart residents and the Department of Transport has conducted a National Travel Survey (NTS) that has helped the We Heart Hart (aka We ♥ Hart and We Love Hart) campaign to calculate the impact of all of these extra houses and extra cars.

The SHMA says that we can expect around 2.5 people per household, the SHMA appendix gives a split of how Hart residents travel to work and the NTS says that work related travel accounts for only 18% of journeys.  Of course people need to go shopping, play sports, visit friends and relatives, go to clubs and societies and ferry around their children and so on.

Using the 2011 numbers it is possible come up with the extra journeys 5,000 extra houses will generate.  Of course, these numbers will need to be doubled if they go ahead with the new town and Hart has to act as a sink for the 3,100 extra houses that Surrey Heath and Rushmoor say they cannot build.  This is shown below.

Extra Journeys Arising from New Town in Hart

Extra Journeys Arising from New Town in Hart

Using this data, you can come up with an estimate of the impact of all these extra journeys will have in terms of increased traffic in Fleet, Church Crookham, Hartley Wintney and Hook because of the routes people will have to follow to get to those destinations.  Of course, there will be also extra train journeys, giving rise to 775 extra commuters going to London each day without even estimating the other non-work related journeys:

Impact on Fleet, Church Crookham, Hartley Wintney and Hook

Impact on Fleet, Church Crookham, Hartley Wintney and Hook

This is of course a very rough and ready estimate, and Hart will no doubt have to find a way of doing some better modelling.  But this gives an indication of the impact which is far from trivial.

Surely it is very important that the impact of building 5,000 houses in a new town, or more than 10,000 if Surrey Heath and Rushmoor get their way, is properly assessed by the council before they finalise the local plan.  Not only that there are going to be thousands of new houses in neighbouring areas like Basingstoke and Deane, Reading and Waverley.  All of these houses are bound to increase the traffic even further in Hart too.

Of course everyone has sympathy for the level of development Fleet, Church Crookham, Crookham Village  and Hook have had to endure over the past few years.  But it is clear that building a new town in Winchfield will only add to the problem of congestion for those areas and the councillors who think they are getting a free-ride from a new town need to think again and start campaigning for fewer houses to be built in Hart.

Download a poster: http://wehearthart.co.uk/home/get-involved/

Sign the petition: https://you.38degrees.org.uk/petitions/we-hart

Like us on Facebook: https://www.facebook.com/groups/IHeartHart/

Follow us on Twitter: https://twitter.com/WeHeartHart

Challenging the SHMA

[These arguments have been expanded and refined on this page. ]

The following questions about the housing allocation for Hart were asked at the council meeting on 27 November.

This post refers to the Strategic Housing Market Assessment and its Appendix that are published on the Hart Website here:

(http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/HRSH%20Consultation%20Draft%20SHMA%20May%202014.pdf  and

http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/HRSH%20Consultation%20Draft%20SHMA%20Appendices%20May%202014.pdf ).

Process

 

  • Background: I would like to understand the process that was adopted to select Wessex Economics to conduct the SHMA. Their website (http://www.wessex-economics.co.uk/about/ ) indicates that they have extensive experience in the property sector, but the principal’s background is with DTZ a leading provider of services to investors and developers.  I am concerned that such a company will be biased towards “development” and not sympathetic to the needs of local people or the environment. Question:  What process was followed to select Wessex Economics and what process was followed to determine that Wessex did not have inappropriate relationships with or financial interests in any housing developers?
  • Background: In the appendix (A1.2), the process for stakeholder engagement is set out. The only people consulted were from local authorities or from developers and housing associations or their representatives.  If the main people consulted are the salivating developers, it cannot be a surprise that their input errs towards the need to build more.  Question: How can the SHMA be a truly Objective Assessment of Housing Need if the main consultees have a vested interest in the outcome?
  • Background: The SHMA is still in draft form on the Hart website. Question: Why is such a fundamental document as the Strategic Options for Housing Growth is being based on a flawed, unchallenged, draft document?
  • Background: Section 1.6 of the SHMA says “For a local plan to be considered sound in terms of overall housing provision, it first needs to have identified the full, objectively assessed need for housing in the housing market area. Local authorities then need to meet these needs in full and demonstrate how they will be met, or provide robust evidence that they cannot be delivered.Question: What evidence is the council producing to demonstrate the objectively assessed housing need is not deliverable?
  • Background: The starting point for the SHMA is the CLG forward population projections. These essentially project forward past trends.  Question: Notwithstanding this is the “preferred approach” in the NPPG, what evidence is there that basing the future need of an area on past population growth is the best or most desirable approach and has the council considered working with other councils to challenge the government mandated approach in the courts?
  • Background: Most of the consultation feedback from developers was against Option 4. The only developer in favour was Barratts and they produced an expensive glossy brochure as part of their submission.  Question: Please set out all of the contact between the council (meaning council officers and councillors) and Barratts in the period from one month before the SHMA was commissioned and 31 October 2014, and all of the contact between the council (meaning council officers and councillors) and all other significant developers for the same period.

 

Content

 

There are a large number of tautologies and flawed assumptions in the SHMA which I would like to draw out and thus challenge the overall conclusion.

 

  • Background: Surrey Heath and Rushmoor are both more highly developed than Hart.  Question: What is the rationale for grouping largely rural Hart with such heavily built up areas?  Would it not be more appropriate to group Hart with more rural districts to the west and south?
  • Background: The report uses as it starting point for the OAHN the official government projections for the number of households in the Housing Market Area (HMA) that includes Hart, Rushmoor and Surrey Heath which states that the total number of new homes required per annum is 790. The report then states that the ONS usually understates these requirements so it makes an arbitrary adjustment upwards to 925 homes per annum.  However, the government website (https://www.gov.uk/household-projections-notes-and-definitions-for-data-analysts ) states that “The current methodology in England reflects work to improve the household projections outputs and methods to better meet user needs”.  Question: What is the justification for a small economics consultancy to challenge the official government figures when the government itself asserts that it has improved its methods and outputs, especially when the assumption leads to an additional 135 dwellings per annum being required across the whole HMA over a 20 year period, a total of 2,700 dwellings?
  • Background: The summary in section 3 notes that the level of household growth in Hart at 10% over the past 10 years has been higher than the regional and national averages. This growth in households can only have been accommodated by new building (e.g. Elvetham Heath in Fleet and St Mary’s Park in Hartley Wintney).  Question: Why is it that we need to base our future housing need on past rates of development that were above the regional and national average, this can only lead to the conclusion that over time, more building will lead to even more building which is absurd and cannot be “sustainable”?
  • Background: Section 7 of the report deals with migration into and out of the Surrey Heath, Rushmoor and Hart Housing Market Area (HMA). Figure 7.5 draws a correlation between migration and housing completions.  In essence, if you build more houses more people will come to the area.  This is perhaps an obvious point.  For Hart in particular, they use the years of 2005-2010 as the years that are most representative of the trend of migration (years in which significant building in Elvetham Heath and other places was taking place).  More recent trends in Figure 7.4 shows a slowdown of migration and indeed a net outward migration from Hart during 2009-2011 and a net outward migration from the whole of the HMA in 2011-12.  In essence they are saying in para 7.35 that we must assume levels of house-building during the credit boom (itself hardly sustainable) to support the population growth of that time in order to predict future population growth for which we will then need to build even more houses.  This is an absurd tautology which leads to a gross distortion of underlying need.  Question:  Why are we basing future need on the years with the highest inward migration that happened during an unsustainable credit boom, and not the most recent years with lower migration which will lead to a more economically and environmentally sustainable solution?
  • Background: Figure 7.7 shows that the trend in household size as measured by the census is slightly upward for the period from 2001 to 2011. However, all of the forward projections reverse this trend and predict a further fall in average household size without any justification.  Wessex have taken some mid-point of the CLG projections.  Question: Why can’t we base our projected household size on the most recent Census data rather than data that is 30 years old and thus reduce our OAHN?
  • Background: Para 7.63 assumes as its base level a higher rate of future job growth (700 p.a.) in the future than was achieved (650 p.a.) during the exceptional, unsustainable boom years of 1998-2008 when our rate of building was already above regional and national averages. Paras 7.68 and 7.69 then further exaggerate the future level of job growth by suggesting it could rise to 1,560 jobs per annum, more than double the Scenario 1 estimate which is based on employment growth that occurred during the largest, unsustainable credit boom in history.  The final jobs growth based estimate used is then a mid-point between the already over-estimated base assumption and the wildly exaggerated high end projection.  Question:  Why aren’t we using employment projections based on more sustainable economic and environmental assumptions which probably ought to be lower than those achieved between 1998-2008?
  • Background: Para 7.81 sets out six ways in which jobs can increase without increasing the need for additional housing. Para 7.83 says the modelling has taken account of only one of those factors.  This again has the impact of increasing the housing stock required in the OAHN.  Question: Why can’t we take account of all six ways in which jobs can increase without building more housing?
  • Background: Figure 8.9 suggests Hart needs to build around 260 affordable homes per annum if the backlog is to be cleared in five years as part of the overall 370 homes per annum required.  Question: Please explain how building a Barratts estate new town in Winchfield will address this affordable requirement?
  • Background: The demographics of the district are changing. According to the SHMA, by 2031, there will be an additional 10,000 people over 60 (including more than 6,850 over 75) expected to be living in the district and an extra 3,620 people who will be suffering from dementia or have some sort of mobility problem. Section 9 of the SHMA suggests that future housing stock should be built to broadly reflect the existing stock. Evidence from developers such as Churchill and McCarthy and Stone suggests (http://www.mccarthyandstone.co.uk/documents/research%20and%20policy/oorh%20full%20report%20may%202011.pdf  ) that remote estate locations are not good places to house the elderly and infirm.  Question: What evidence base is there to suggest that the needs of the future population will be met by past housing stock?  What evidence has the council collected to determine the best types of accommodation and the best places to build those types of housing to meet the needs of the elderly and infirm?
  • Background: Para 7.119 states the following “These market signals point to the need to identify and address the demographic and economic need for housing; they do not themselves provide a quantifiable need for housing (and indeed there is no recognised methodology for this)”. Question: If there is no recognised methodology for providing a quantifiable need for housing, why are we following an approach that is artificially inflating the housing need for the area that will inevitably lead to the destruction of the most attractive parts of the district?
  • Background: The Localism Act requires local authorities to maintain a list of assets of community value which have been nominated by the local community. Question: Where can the Hart register of assets of community value be found, and can I nominate the Winchfield area as an asset of community value?
  • Question: Can the council please commence activity to protect the Winchfield area as Green Belt on the following grounds:
    • To check the unrestricted sprawl of built-up areas.
    • To safeguard the surrounding countryside from further encroachment.
    • To prevent neighbouring towns from merging into one another.
    • To preserve the special character of historic towns.