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?

A: There could be benefits to having a standard approach to assessing the need for housing, but
a formula drawn up by the Government can never fully understand the complexity and
unique needs of local housing markets, which vary significantly from place to place. It is
crucial that councils and communities can lead new development in their areas.

The consultation runs until the beginning of November and we shall use that time to assess
the robustness of the government’s draft proposals to understand how it would meet all our
housing needs such as the need locally to deliver affordable homes for example. We intend
also to work with out Housing Market Area Partners and with other partners, such as the
District Council Network and the Local Government Association, to formulate our
response to the consultation.

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

A: We will endeavour to put as much in the public domain as soon as possible.

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?

A: The point about using the methodology immediately is not strictly true. The Government’s
paper is a consultation only on a possible standardised methodology. Clearly one cannot
prejudge the use of a possible methodology prior to the end of the consultation whilst also
speculating on the outcome. In any event, the consultation makes it clear that only if
adopted, the new methodology will only take effect for Local Plans submitted either after
1 April or when the new revised National Planning Policy Framework (NPPF) is published
(whichever is the later). It would clearly therefore be premature at such an early time to
start to speculate wildly about the possible use of an methodology that has not yet even
been agreed.

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

A: The Governments’ paper is a consultation and consultation only – one should not speculate
about the outcome. It would therefore, be totally unwise to start to speculate about how
our market area partners would react to the consultation and what that may mean for
future unmet housing needs particularly as Surrey Heath is already well behind in meeting its
current needs.

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

A: The current arrangements for calculating housing need remain in place until such time as the
methodology for calculating housing need is changed by the Government. The objectively
assessed housing need for Hart remains at 382 new homes/annum but we agree with the
previous administration that an affordable housing uplift is essential and that we should be
planning to deliver at least 485 new homes/annum.

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?

A: Not all districts are the same and we are not starting from the same point, This
consultation ends in November, with the results not available until the new year, and we
need to progress our local plan process rather than waiting for these consultation results. If
you need more detail please get in touch with me and I will try to help.

Hart major planning site update

Hart Major Planning Site: Hartland Park (Pyestock) Master Plan

Hart major planning site: Hartland Park (Pyestock) Master Plan

This post will provide a Hart major planning sites update. We will cover:

  • Hartland Park (Pyestock)
  • Pale Lane (Elvetham Chase)
  • Grove Farm (Netherhouse Copse), Fleet
  • Cross Farm

Hart Major Planning Site: Hartland Park (Pyestock)

The first Hart major planning site is Hartland Park. This is the site of former Pyestock National Gas Turbine Establishment. Hart Council’s planning committee has agreed to the principle of building up to 1,500 new homes on this brownfield site.

Hart Major Planning Site: Hartland Village

Hart Major Planning Site: Hartland Village

The decision is subject to a number of conditions:

  • Hampshire County Council withdrawing its highway objection.
  • Confirmation of viability issues associated with affordable housing.
  • Securing appropriate SANG land.
  • Further consideration by the Major Sites Sub-Committee.

Our views on Hartland Park

We agree with this decision in principle, but echo the council’s concern about a number of items:

  • The developer is proposing only 20% Affordable Housing. We would like to see more affordable housing and especially some social housing for those who can’t rent and can’t buy.
  • We are concerned about the road network and therefore think Kennels Lane should be upgraded to provide a relief road around the site
  • There should be a proper cycle/walking route installed to provide easy access to Fleet station.

We will continue to monitor this development.

Full documents on Hart’s planning site can be found here.

Hart Major Planning Site: Pale Lane (Elvetham Chase)

Pale Lane (Elvetham Chase) planning application dates

Pale Lane (Elvetham Chase) planning application dates

Second up is Pale Lane aka Elvetham Chase. This is an application for 700 new houses near Pale Lane, between Elvetham Heath, the railway and the M3. The controversial planning application was submitted for this site back in November 2016. The deadline for determination passed months ago, but it seems as though the agreed date for determination was changed to September 15 2017 by agreement with the developer. Sadly, no decision has been forthcoming because the site wasn’t even considered at the planning meeting held on 13 September.

There is therefore a risk that the developer will launch a “Non-Determination” appeal just like those that were launched for Grove Farm (Netherhouse Copse) and Cross Farm.

Consequently, we are concerned that the council seems to be missing the deadlines for these major applications.

Full documents on Hart’s planning site can be found here.

Hart Major Planning Site: Grove Farm (Netherhouse Copse)

[Update] This site has been approved for development by the planning inspector [/Update] The third Hart major planning site is Grove Farm (Netherhouse Copse). This is an application for 423 new houses on the site off Hitches Lane in Fleet. The appeal for this site was heard back in July. The Planning Inspectorate had published a document on its website saying the appeal decision would be made public on September 15 2017.

Hart Major Planning Site: Grove Farm (Netherhouse Copse), Fleet, Hart District, Hampshire Appeal Dates

Grove Farm (Netherhouse Copse) Appeal Dates

Sadly, this deadline has not been met. We Heart Hart understands the decision will now be made on or before October 6 2017, although the website is now ambiguous.

Full documents on Hart’s planning site can be found here.

Grove Farm (Netherhouse Copse) Appeal

Grove Farm (Netherhouse Copse) Appeal

We can live in hope that the Government’s announcement on the new housing need methodology will influence the decision in a positive way.

Hart Major Planning Site: Cross Farm

[Update] The appeal and planning application have been withdrawn] Finally, we have Cross Farm. This is an application for a 160-unit care village in Crookham Village. This was supposed to be determined a few months ago. The council failed to make a decision on time and the developer launched an appeal. The council did say it would fight the appeal, going against it’s own draft local plan.

Hart Major Planning Site: Cross Farm Appeal withdrawn

Cross Farm Appeal withdrawn

However, it now appears as though the appeal has been withdrawn, so it isn’t clear whether the site will be in the next version of the Local Plan or not.

Full documents on Hart’s planning site can be found here.

Conclusion

All in all this is mixed news for the Hart major planning sites. First of all, we are pleased Hartland Village has passed one of the planning hurdles. Yet, we are concerned about the lack of decision on Pale Lane (Elvetham Chase). It is frustrating that no decision has been made in the Grove Farm (Netherhouse Copse) appeal. Finally, the Cross Farm application seems to be in limbo, with no formal decision by the Council and the withdrawn appeal.

We do hope that the three green field sites are dropped as a result of Hart’s housing ‘need’ being reduced due to the new Government methodology.

 

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.

 

 

 

 

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.

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]

Hart Tories claim victory despite abject failure

Hart Tories (NE Hampshire Conservatives) claim victory despite abject failure

Hart Tories (NE Hampshire Conservatives) claim victory form abject failure

North East Hampshire Conservatives have managed to claim victory, despite their abject failure to plan for a sensible amount of housing for Hart District.

On Thursday, the Conservative led Hart Cabinet agreed to plan for more than 10,000 houses. This is many more than is required to meet the needs of Hart residents. Yet, because they have managed to avoid putting those houses near Fleet, they claim it as some sort of victory. They show no concern for Hart residents who live in the more rural areas.

Apparently, the Hart Tories are concerned about over-development, transport, traffic, education, loss of green space and the impact of development on existing infrastructure. But only in the immediate area around Fleet. The rest of us will just have to suffer.

To recap, to meet the demographic projections for Hart residents and meet the needs of those who can’t get on the housing ladder, we need to build 6,000-6,500 new dwellings. Anything over and above that requires massive in-migration to Hart. That is, massive in-migration of people whose housing needs are supposed to be met elsewhere. The SHMA also assumes that most of these people will work outside the district, putting even further pressure on local infrastructure.

Hart is planning for more than twice the demographic projections. They are not alone, other nearby districts are planning for 42% more houses than the demographic projections require.

However, their so-called victory may be short lived. The Grove Farm application is being appealed by the developers. The Planning Committee also has to make a decision about Pale Lane soon. It seems likely that they will turn it down. However, it seems equally likely the developer will appeal that decision too. With no Local Plan, out of date policies and a questionable 5-year land supply, the inspector may well grant permission for both these sites.

The only sensible way out of this, is to remove the extra 2,000 houses they voted through on Thursday and demonstrate that the houses are not required.

New Hart SHMA published: housing target rises despite falling population projections

The Scream - 2016 New Hart SHMA also covering Rushmoor and Surrey Heath

The 2016 new Hart SHMA also covering Rushmoor and Surrey Heath has been published and Hart’s housing target has been increased from 7,534 to 8,022. This increase comes despite the forecast population for 2032 being lower than assumed in the 2014 SHMA.

For those uninitiated in the terminology of the Local Plan, the SHMA is the Strategic Housing Market Assessment. This is the totally objective document that is entirely above any criticism because it is produced by consulting only those who have a vested interest in building more houses.

Just like the last SHMA, a number of spurious assumptions and arbitrary uplifts have been applied to artificially increase the housing target to 53% above what we would need if we stuck to the demographic projections.

Essentially, we are being asked to concrete over our green fields to build houses for people who need to move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. Other districts should already be planning to house those people.

Here is the summary of how they did it, followed by our critique of the methodology and results:

2016 new Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

Demographic Startpoint

They have used the 2012-based population projections to arrive at the 785 dwellings per annum for the whole housing market area (HMA), consisting of Hart, Surrey Heath and Rushmoor. This results in a housing need of 254 dwellings per annum or 5,334 for the whole planning period up to 2032. Already most of this target has been built or permitted in Hart. If we stuck to this, we would not need to grant permission on any of the sensitive green field sites like Grove Farm (Netherhouse Copse), Elvetham Chase (Pale Lane), Owens Farm (West of Hook), Murrell Green or Winchfield.

However, even this starting point is inflated. The new SHMA states that if they used the 2014-based population projections instead, then the starting point would fall by 94 dwellings per annum for the HMA as a whole. The target would fall by 41 dpa for Hart, or a total of 861 dwellings.

2016 New Hart SHMA Figure 6 Appendix H impact of 2014-based SNPP Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 6 – Appendix H: Impact of 2014-based SNPP projections

Market Signals Uplift

This starting point is then inflated for ‘market signals’ and affordable housing requirements. We agree that there is evidence that younger people cannot get on the housing ladder, or in some cases cannot even rent properties in the area because property prices are too high. The uplifts they recommend increase the target by ~15%, resulting in 903 dpa for the HMA and 292 dpa or a total of 6,132 for Hart. Again, the remaining target for Hart could easily be met from brownfield development at Pyestock (Hartland Village) and Sun Park.

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

However, we do challenge the methodology they have applied in this case. They run two scenarios to estimate the extra houses required to meet the needs of people who are apparently not forming households at the expected rate. These would result in a 7-14% increase in the number of houses.

However, they arbitrarily choose a 15% uplift, which is larger than either of their modelled scenarios.

Even the SHMA itself calls into question whether this uplift will actually achieve anything:

9.72…Of course, there is no way of knowing in advance exactly how improvements in housing affordability would increase household formation rates (if at all)

Moreover, there is no evidence at all that simply allocating more land for development will either increase the number of houses being built or reduce the price of housing. The same section shows that development land in Hart, with planning permission costs £4.1m per hectare (section 9.12). At Hart’s preferred housing density of 30 dph, this equates to the land cost alone of a new home being around £133,000.  Build costs, S106 contributions and a profit for the developer could easily see the sale price of new homes being around £400,000. If housebuilders cannot achieve this level of pricing, then they simply won’t build the houses.

Affordable Housing Uplift

Some further adjustments are then made to lift the housing target 985 dpa for the HMA, or a further 24 dpa (504 in total) for Hart resulting in a total of 6,636 over the whole planning period. Even if this adjustment were accepted, this would still be easily accommodated on brownfield land in Hart.

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

There are two issues with this approach. First, column G shows there is a net negative need across the HMA, but Rushmoor needs to find 84 dpa. These are arbitrarily shared amongst all three districts, even though there is no net need across the three districts as a whole. Second, the whole analysis appears to double count the housing uplift for market signals above in that the ‘concealed families’ are already accounted for in the market signals analysis.

Accordingly, we believe this adjustment should be removed from the calculation.

Jobs Growth Adjustment

The most egregious adjustments come from the jobs growth adjustments. The total housing requirement is increased to 1,200 dpa for the HMA. This results in 382 dpa for Hart or a total of 8,022 new houses over the planning period. This increase means it is likely we will have to allocate green field land for development.

We have a number of 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.

Second, the projection of 1,200 jobs per annum is far in excess of 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, they use a very circular argument to account for the number of jobs. The argument is basically, 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. So, they then decide we will need to import some extra people and those people will need houses. Clearly, this is not an expression of the ‘need’ for the district.

However, the population projections already assume inward migration from other areas and international migration from abroad. Note that since the Brexit vote, migration from the EU is likely to fall, so these projections may well overstate the level of international migration.

These additional people must be coming from other areas. However, we know from analysis of other authorities that they are also increasing their housing targets by around 42% above the demographic projections. So, the question remains, where will the people come from to live in the extra houses? All local authorities need to meet their own local needs, so if all local authorities plan for far more than they need, we will have too many houses, but we will have concreted over our countryside.

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. And other districts should already be planning to house those people.

It is a farce. This adjustment to the housing targets should be removed.

2016 New Hart SHMA Conclusions

We believe a realistic housing target for Hart is around 6,000. This would meet the needs identified from the most up to date population projections and give a sensible allowance for additional houses to cater for ‘concealed households’ and the younger people who want to get on the housing ladder. Affordability will come from building more smaller properties and taking advantage of the Government Starter Homes Scheme.

This housing target will mean we can build all of our remaining requirement on brownfield sites and still have many brownfield sites available for future generations.

However, given the perilous state of the Local Plan, we can’t simply ask for this to be redone. We must argue in the consultation about the new Local Plan that the housing target in the SHMA is too high, and therefore the plan does not need to allocate as much green field land for development. We have no doubt that there will be a number of developers arguing for an even higher target.

The new Hart SHMA and appendices are available for download below:

Hart Rushmoor & Surrey Heath 2016 SHMA
Hart Rushmoor & Surrey Heath 2016 SHMA Appendices

 

 

 

 

Status of Hart Local Plan set out in email to parish councils

Hart District Local Plan delayed again

The current state of play of the Hart Local Plan was set out in an email to Parish Councils last week.  We reproduce it below with our commentary in [bold italics]

Dear All, I am writing to update you on the current position with regard to the Hart Local Plan.

The Council’s overall strategic position on the Local Plan was agreed in October 2016.  It is to:

“Seek to meet Hart’s full, objectively assessed need for new homes, subject to the inclusion of an appropriate contingency to allow for any delays or the non-delivery of sites, and that it will also seek to accommodate any demonstrated unmet need for new homes from its Housing Market Area partners, and additionally provide for essential infrastructure including a site for a secondary school”. 

We have a Local Plan Steering Group (LPSG) that was set up by Cabinet and comprises a small Core Group of Members (The Leader, the respective Portfolio Holders for Planning and Housing, all Group Leaders, and the Chairman of Planning Committee). The purpose of LPSG is to advise Cabinet on Local Plan matters. It is not a decision making body. LPSG meetings are not held in public but the meetings are not secret and the minutes of each meeting are reported to Cabinet. The meetings are also open to all Councillors to attend and Stephen Parker, as Chairman, has encouraged all present to participate.

The latest meeting in December (LPSG minutes attached) tested the Policy Planners recommendation that we should support a potential option (which we called Option 3a) that included a possible small new settlement, urban extensions and a balanced distribution of new homes across the District. [We believe this included Murrell Green, Grove Farm and Owens Farm to the west of Hook. We understand Winchfield and Pale Lane (Elvetham Chase) were specifically excluded]. A site for a secondary school was also identified. In principle Option 3a would have accorded with the strategic aims agreed by the Council in October 2016. If agreed it would have resulted in a draft Plan being progressed to Council at the end of January with a view to it all going out to public consultation.

Whilst Option 3a still lies on the table the consensus from the recent LPSG meeting was that Option 3d (a larger new settlement and distribution option) [We believe this brought Winchfield back into the equation. The likely timescales would probably mean that Grove Farm and some combination of Pale Lane and Owens Farm would be required] should be revisited [We understand the driving force behind this initiative was Concrete Community Campaign Hart, who seem intent on derailing the whole process]. This was because the recent Housing Options consultation had confirmed that the public’s first preference is for future growth to be focused on the delivery of a new settlement [Actually the council stated its first preference was for brownfield development, but did not give the public an opportunity to vote on that solution].  The least preferred option was for more urban extensions. The broad cross party consensus was that we should look to avoid delivering urban extension and Option 3d would in itself be an alternative way of delivering the strategic aims agreed by the Council in October 2016.

At the moment we are reflecting upon this. We are reviewing the two options and we will consult shortly on one of them. At the time of consultation we will offer a briefing to all Parish and Town Councils. We are also testing the need for any affordable housing uplift [This is the rumoured 2,155 extra houses to meet an alleged need for 800+ extra affordable homes] which is also an new approach that is being recommended to us by the Policy Planners. It does have an implication for how many new homes that we should built but it does reflect issues that have been raised by Inspectors at recent Local Plan examinations. We need to consider it further and a policy decision made by the Council about whether it agrees to follow it. This testing may require a little additional work and re-evaluation of delivery timescales and trajectories. More information is being submitted to help us with the evaluation.

In the meantime Officers are keen not to undermine the democratic processes by engaging in a public debate [!!!!!] in advance of the District Councillors themselves having formed a view about how they wish to see the way forward [Perish the thought that councillors be involved in a debate with the public] . There is absolutely no benefit in seeking to rehearse decisions that have not yet been made and I’m sure that everyone would agree that it would not be right for Officers to engage in what is in effect political speculation.

We understand form elsewhere the delay to the Local Plan will be 4-6 weeks, or longer. Given that five of the six weeks have already all but gone by since the LPSG meeting on 13 December, we shall not be holding our breath.