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.

CCH force delay to the Hart Local Plan as housing numbers rise

CCH force delay to Hart Local Plan- this is no time to keep calm

This is no time to keep calm

We Heart Hart has learned that last night’s meeting of the Hart Local Plan Steering Group was a”disaster”.  Concrete Community Campaign Hart (CCH) councillors forced a further delay on to the timetable by insisting that Winchfield New Town is included as an option.

Affordable Housing blow

In a further blow, it appears as though Hart’s housing allocation has been further inflated by up to 2,000 additional houses due to new Government guidelines that may force Hart to build even more ‘Affordable Homes’. This new requirement would be in addition to the 40% of homes that must be ‘Affordable’ in the SHMA target.

Apparently, there are no plans to publish the new Strategic Housing Market Assessment (SHMA) until they are ready to publish the Regulation 18 consultation on the new draft Local Plan. We don’t know the timescale for that yet.

This shows that Hart’s statement in October that Hart had to build 1,500 fewer houses was a total sham.

Impact of Delay to the Hart Local Plan

There were three potential options on the table at LPSG for detailed consideration. However, CCH insisted on a fourth option that included the Winchfield New Town. We don’t know the specifics of the other options, but we suspect they included Grove Farm/Netherhouse Copse.

WeHeartHart had been led to believe that the Winchfield New Town option failed testing due to concerns about groundwater flooding and lack of infrastructure. The level of testing that was carried out is now in doubt. It is difficult to see how a further delay and more testing is going to change the viability of the new town.

CCH’s stance is strange because the delay to the Local Plan will weaken Hart’s defences against the speculative applications being submitted by developers. The proposed developments at Grove Farm/Netherhouse Copse and Bramshill House are due to be determined at tonight’s Planning Committee meeting. Of course, an application to develop the Pale Lane site into Elvetham Chase has recently been submitted and this will need to be determined in the New Year. If there is no draft Local Plan, then it will be difficult to defend against it.

Conclusion

It is imperative that we get the Hart Local Plan in place quickly so we can manage the inevitable housing growth that we face. CCH should stop their ideological pursuit of the unviable Winchfield New Town and start to work constructively to solve the problems of the whole district.

We would wish to see many new homes that are truly affordable for Hart residents. However, there is strong evidence of developer land-banking in Hart and of not building enough smaller properties. Simply increasing the housing target won’t lead to a meaningful increase in housing supply. Even the smallest properties at recent developments (for instance Rifle Range Farm/Hartley Row Park at Hartley Wintney) were out of reach of most Hart residents. We think the new additional target for affordable homes should be vigorously challenged.

Stop the Elvetham Chase Development Facebook Group Launched

Wates Homes Elvetham Chase (Pale Lane) Development Proposal, near Elvetham Heath and Hartley Wintney, Hart District, Hampshire.

Elvetham Chase (Pale Lane)

A new Facebook Group called ‘Stop the Elvetham Chase Development’ has been launched to oppose the proposed Wates development near Pale Lane, straddling Elvetham Heath and Hartley Wintney parishes. The site also borders the Winchfield parish.

The group already has 315 members and can be found here.

Please do all you can to support them. They need another 30 or so objections to get to their target of 120.

The application is for outline planning permission for 700 dwellings at Pale Lane (also known as Elvetham Chase). More details of this application can be found here and searching for application reference 16/03129/OUT

It will be interesting to see if this site is on Hart’s preferred list at the ‘spatial strategy’ discussion at tonight’s meeting of the Local Plan Steering Group.

Hart Local Plan and planning application update

Hart Local Plan and planning application update

There is a great deal of activity behind the scenes about the Hart Local Plan. The timetable for delivery is becoming clearer and there are updates on a number of planning applications that will shape the future of our district.

Hart Local Plan Timetable

We Heart Hart understands the upcoming timetable for the Hart Local Plan is as follows:

During w/c 28 November: The new Strategic Housing Market Assessment (SHMA) will be sent to councillors.

29 November 2016: Local Plan Steering Group (LPSG) Meeting, where we understand the timetable for the Hart Local Plan will be discussed and drafts of new Planning Policies will be considered.

December 13 2016: A further LPSG meeting will be held to review the draft spatial strategy. This will set out the number of houses we need to build and suggest where they will be built.

December 14 2016: We understand that the planning application for 423 houses at Grove Farm (aka Netherhouse Copse) near Crookham Village to the west of Fleet, will be considered at the Planning Committee. It is possible that some of the applications to redevelop the former Police College at Bramshill House will be considered.

January 26 2017: Draft Local Plan to go to full Council.

Upcoming Planning Applications

The long standing application for around 550 houses to the North East of Hook was finally signed off on 21 November.

The application for 423 houses at Grove Farm (aka Nether House Copse), near Crookham Village will be considered at the Planning Meeting on December 14. More details of this application can be found here and searching for application reference 16/01651/OUT.

It is possible that some of the applications for redevelopment of the former Police College at Bramshill House will be considered. There are a number of applications outstanding on this site that can be found here. The main applications appear to be 16/00726/FUL for 235 units and 16/00721/LBC for 25 units. At least this is a brownfield site, although controversial, being so close to the Thames Valley Heath SPA.

This week, Wates submitted an outline planning permission for 700 dwellings at Pale Lane (also known as Elvetham Chase). More details of this application can be found here and searching for application reference 16/03129/OUT

Conclusions

We don’t yet know how HDC are going to treat these applications, or if they have other ideas for strategic locations for additional housing. Of course, we await an application to redevelop the brownfield site at Pyestock (Hartland Village) and of course Winchfield has been mooted as a site for a new town, but we believe this has failed testing. Other strategic sites that were being considered include Murrell Green (between Hook and Hartley Wintney), Lodge Farm and West of Hook. Of course proposals are also being developed for the so called Rye Common New Village.

It is galling to say the least that we are seeing so many applications on greenfield sites instead of brownfield sites. It is imperative Hart produces the new Hart Local Plan and the new Planning Policies ASAP. This will allow us to regain control over where houses are built in the district.

 

Fleet News demands action on Local Plan as Hart comes under siege

Fleet News Hart must get a Local Plan in place now

Today’s Fleet News has run an important series of stories on the sorry state of the Local Plan in Hart District. Most importantly, they have run a comment piece demanding that Hart get the Local Plan in place now to protect us from the voracious developers who are putting Hart under siege by developing proposals for big green field developments we don’t need at places like Winchfield, Murrell Green, Pale Lane (Elvetham Chase), Grove Farm (Nether House Copse) and now the Rye Common new village proposal.

If one or more of these green field developments goes ahead before an application is made to redevelop the Pyestock (Hartland Village) site we may well end up with our green fields been ripped up whilst the derelict brownfield site is left undeveloped.

But without a new Local Plan and without up to date policies, Hart is essentially defenceless against the proposals. Moreover, the further delay to the Local Plan means that there is a real risk the Government will step in to do the Local Plan for us if the plan is not in place by early 2017.

The articles from Fleet News can be found on the links below:

Hart under siege from developers’ plans to build over Hart

Hart must get a Local Plan in place now

Hart District Council slashes number of new homes