Reply received from local MP Ranil Jayawardena

Ranil Jayawardena at a brownfield site

Ranil Jayawardena at a brownfield site

You may recall that before Christmas we wrote to our local MP, Ranil Jayawardena setting out concerns about how the planning system is working for Hart. The letter we sent can be found here.

We have now received a reply from Ranil which is reproduced below. We don’t agree with some of it, but it is good to see that he has produced a substantive reply. Links to even larger versions of the images are at the bottom of the post. We will produce a more substantive reply soon.

Reply from Ranil Jayawardena Page 1 of 3

 

Reply from Ranil Jayawardena Page 2 of 3

 

Reply from Ranil Jayawardena Page 3 of 3

 

Page 1, here

Page 2, here

Page 3, here.

Open letter to Ranil Jayawardena, Sajid Javid and Gavin Barwell

Ranil Jayawardena Stephen Parker and Michael Fallon meet at Pyestock (Hartland Park or Hartland Village

Below is the text of an open letter sent to our Local MP, Ranil Jayawardena asking for his help to make changes to national policy to help Hart come up with a more realistic Local Plan and help fend off the threat of too many houses.

Let’s see what happens.

Dear Ranil,

To date, I have been very impressed with you as our local MP. You seem to be well in tune with your constituents and your campaign to promote more brownfield development in our area is to be commended.

I know that, quite rightly, you are reluctant to get involved in local planning matters because they are the responsibility of the local council. However, I am writing to you today to ask for your support in changing some elements of national policy that should help Hart District Council produce a more realistic Local Plan.

There are four main sections to this letter:

  • Process and outcome of assessing housing need
  • Affordable housing
  • Infrastructure contributions
  • Suggested policy changes

The links in the text take you to more in depth research, mostly from the WeHeartHart.co.uk website, which I run, to support the assertions made. I have also copied this letter to the ministers responsible for this area of policy and the leader and joint-CEO of Hart Council.

Assessing Housing Need

 

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 130-150,000 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.

However, there is increasing evidence that house builders have too strong an influence over the process that is leading to housing market assessments being artificially inflated to a level much higher than that required by the national household projections.

In Hart, the 2014 Strategic Housing Market Assessment (SHMA) is currently being revised to take account of more up to date population and household forecasts. However, I believe the process being followed will be largely the same as before.

The way it works is as follows. The raw household forecasts are subject to a set of dubious adjustments and convoluted calculations to arrive at a spurious objectively assessed ‘need’.  In the case of the 2014 SHMA, the outcome was ~7,500 houses. For the SHMA area as a whole this results in an uplift to the raw DCLG household forecasts of more than 50%.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 305,000 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”.  I did make a FOI request to the DCLG to provide the national figures, but this has been refused on the grounds that DCLG “does not hold this information”. Given the importance that is being placed on housing delivery, it is quite staggering that central Government is not collecting the data to allow it to monitor the results of its own housing policy.

The experience of the Hart, Surrey Heath and Rushmoor SHMA is by no means unique. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the baseline household projections of around 42%.

A further illustration of the absurdity of the calculations used in the 2014 SHMA is contained in its own appendix.  This clearly shows that if the more up to date 2012-SNPP number were used, the starting point for Hart would fall from 337 to 247 dwellings per annum or a fall of 1,800 units over the plan period.

Taken together, these results show that the process for producing the SHMAs is fatally flawed and cannot be justified.

There might be some justification if this process had actually 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 this year there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

It is clear that creating ever increasing housing targets is merely encouraging ‘land-banking’ by builders, who then build at a rate to maximise their own profits.

Imagine my surprise to find out that one of the outcomes from Hart’s yet to be published revised SHMA is that the housing target is going to be raised again to over 10,000 units (although this is being further examined by the council). Yes, you read that correctly: despite the starting point being based on the more up to date population forecasts described above, that should result in a ‘need’ of 1,800 fewer houses, the target is going to be raised 30% above the earlier ‘need’ and nearly 100% above the new starting point.

Apparently, there are some further arbitrary adjustments, some other sophistry and some new guidance from Government about the provision of so called ‘Affordable Homes’ that means in order to satisfy a shortfall of ~800 affordable homes, we must build over 2,000 more new houses in total because the affordable component cannot be more than 40% of the total.

The consequence of this change is that it will inevitably mean we can no longer meet our remaining housing need from brownfield sites and will have to sacrifice great swathes of our beautiful countryside to satisfy some bureaucratic pen-pushers rather than the actual housing needs of the district.

This is plainly ridiculous and cannot be allowed to stand. But that leads me on to policy improvements  around ‘Affordable Homes’

 

Affordable Homes

 

Many in Government seem to hold the view that merely calling some houses ‘”Affordable” makes them so. This is clearly an absurd position to take.

Let’s take a local example in my own village.  Recently, Bewley Homes built around 90 new houses in a new development called Hartley Row Park at a reasonably sensible add-on to the village.

The lowest price for a 3-bed semi-detached home was set at £465,000. The lowest anticipated price of the 2-bed homes that were due to be released later in 2016 was £370,000. This means that the cheapest 3-bed house is 11.5 times median income, and the cheapest 2-bed home will be 9.2 times median income.  Even with a 20% ‘Affordable’ homes discount, the cheapest new properties will be totally out of reach of middle-income families in the district.

This is further compounded by the lack of measurement and poor controls over the size of properties bring built. There is clear evidence that Hart is under-building 1-bed and 3-bed starter homes and over-building 4+bed properties. This is doing nothing for the younger residents of Hart, whom the Local Plan is supposed to serve, yet encouraging even more inward migration from London into properties that locals cannot afford. Clearly, the controls needed are really a matter for the local council, but there may be something that can be done at a national level to mandate new developments to meet local needs.

However, there are some national policies that need to be examined, not least the ‘Help to Buy’ scheme, interest rates and QE.

As any economist will tell you, if you subsidise the price of anything, then demand will go up and prices will follow. I find it quite amazing that a supposedly free-market Conservative Government is borrowing to use taxpayers’ money in the HTB scheme to subsidise higher house prices, especially at a time when we still have a massive budget deficit.

But the bigger impact on house prices has probably come from ultra-low interest rates and QE. This inexorable flow of cheap money has artificially raised the price of all assets and property in particular. You cannot hope to bring house-prices to reasonable levels unless and until you address monetary policy.

 

Infrastructure Contributions

 

Hart, like many other places in the country is suffering from creaking infrastructure. Our schools are full, it is difficult to get appointments at the doctors and road congestion is increasing.

According to the latest figures available Hart is running a £78m infrastructure funding deficit, and this is probably an under-estimate as it was prepared before the current, let alone the new SHMA. Key quotes from the document include:

“It is therefore reasonable to conclude that it is unlikely that there will be sufficient future funds, from both capital programmes and developer contributions, within the plan period, to deliver all of the projects listed in the HCC Transport Statement”

“Although developer contributions will continue to play an important role in helping to bridge the funding gap, it is also clear that the funds raised through developer contributions will only contribute a modest proportion of the total identified funding gap”

 “The South West Main Line (SWML) outer trains, which serve Hart, has significant forecasted future peak crowding, with a capacity shortfall of over 6,100 passengers in the high-peak hour, even if every main line train is at maximum length”

It is true that many developments attract S106 or CIL contributions towards infrastructure. However, it is also clear that both ‘Affordable Homes’ and office conversions using ‘Permitted Development Rights’ deliver no such contributions. Overall, the policy mix has delivered a massive funding gap, yet we are expected to continue to even more houses, when the funding delivered is much less than the funding required to bring the infrastructure up to scratch.

This is clearly unsustainable and must change.

 

Suggested Policy Changes

 

As I see it you can help your constituents by demanding policy changes in several key areas:

  • The Government should collect and analyse all SHMAs across the country to monitor that the total of the local ‘needs’ is in line with the overall national totals
  • There should be some greater controls put on the way that seemingly arbitrary adjustments to the starting points are made to ensure they do not go too far above those levels. 20% would seem like a reasonable level to me.
  • Encourage builders to build existing planning permissions faster by introducing a charge equivalent to council tax rates when development has not completed after a specified period of time.
  • Stop subsidising higher house prices through HTB, QE and ultra-low interest rates.
  • Introduce a ‘planning gain levy’ on land owners who make significant windfalls from selling agricultural land for development to fund infrastructure. This would be similar to the original ideas behind “Garden Cities” where landowners helped fund infrastructure
  • Introduce S106/CIL funding for all new development. Every new home has people in it and they all use local infrastructure, so all new development should include some contribution
  • Introduce ‘open book accounting’ to each development and force developers to make increased S106 contributions if they make more than planned profit on a development.
  • Increase Government funding for smaller, local infrastructure projects such as road widening, junction improvement, bridge widening, school building and surgery building. This would be a much better use of money than building white elephants like HS2.

I do hope you find this letter constructive and helpful in understanding the impact of national policy on your local area.

May I wish you and your family a Merry Christmas and a happy and prosperous New Year.

 

Yours sincerely,

 

Ranil supports redevelopment of Pyestock (Hartland Park)

Ranil Jayawardena Stephen Parker and Michael Fallon at Pyestock (Hartland Park)

Our local MP, Ranil Jayawardena has published an article on his website showing his support for the redevelopment of the brownfield Hartland Park (formerly the Pyestock, National Gas Turbine Establishment (NGTE) site, near Fleet in Hart District, Hampshire. Readers will remember, that it is proposed to build 1,500 new homes on this site.

He is pictured with the Secretary of State for Defence, Michael Fallon and leader of Hart District Council, Stephen Parker.

Ranil Jayawardena, M.P., said: “Pyestock is exactly the sort of brownfield regeneration that should be supported. I am pleased that Hart are working together with HM Government to deliver homes on brownfield sites wherever possible, rather than building on green fields.”

Secretary of State, Michael Fallon, M.P., said: “It’s good to see sites like Pyestock being put forward for development. HM Government is ensuring that brownfield regeneration is central to local areas building new homes. A new ‘brownfield register’ is included in the Housing and Planning Bill, which will ensure that development is prioritised on brownfield sites rather than at the expense of the countryside.

We Heart Hart warmly welcomes Ranil’s support for this project. We understand that a site for Suitable Alternative Natural Greenspace (SANG), needs to be found before the redevelopment can go ahead.  Let us hope that Michael Fallon can help find some redundant MoD land to help with this, so it can be included in the Hart Local Plan.

 

Local Elections 2016: Where do Hart candidates stand on new town and Pyestock redevelopment?

We Love Hart Ballot Box

The Local elections will be held on Thursday 5th May, and we thought it would be a good idea to compile a database of local candidates and ask where they stand on two key planning issues facing the district:

  1. Do they still support a new town at Winchfield and,
  2. Do they support the redevelopment of Pyestock (aka Hartland Park) as housing

Community Campaign Hart have launched their election page and have now answered our questions making clear they support the development of Pyestock, but want to ensure safeguards on school places and roads as well as ensuring the SSSI’s and SPA are protected.  However, they still also support a new town in Winchfield.  Their detailed answers and our responses can be found here.

The North East Hampshire Conservatives have always been split on the issue, with many councillors voting in favour of the new town in November 2014, but notably all of the opposition to the new town came from local Conservatives. Of course, our local MP Ranil Jayawardena has opposed the new town idea too. We have had responses from many of the Tory candidates now and it is clear support for the Winchfield new town is weakening, with strong support for the proposed Pyestock development. The detailed answers we have received can be be found here.

The local Greens have now said that all of their candidates oppose the Winchfield New Town and support the redevelopment of Pyestock (aka Hartland Park).  They have also set out some interesting ideas on broader housing policy. The detailed answers we have received can be found here.

North East Hampshire Labour have recently published an article in favour of the new town at Winchfield, stating it is the settled position of all of their candidates. They have also published an article supporting redeveloping Pyestock for housing, but make clear they also support a new town at Winchfield. Our response to that can be found here.

All of the sitting Liberal Democrats on Hart Council all voted in favour of the new town in November 2014.  The Lib Dem County Councillor (David Simpson) opposes the new town, and some local candidates stood on a platform opposing the new town in May 2015. The local Lib Dems have published a newsletter in Hartley Wintney and Eversley opposing the new town idea. They later published a leaflet supporting the redevelopment of Pyestock. We do not yet know if this represents the views of Lib Dems across the district. The posts related to their leaflets are here and here.

We only know the position of the local UKIP candidate for Hook. He opposes the Winchfield new town and supports a brownfield first policy, but has made no definitive statement about Pyestock. However, UKIP have made a statement on their website, supporting a brownfield first strategy, which is recorded in this post.

We have contacted all of the local parties and asked them to clarify their views on the new town and Pyestock.  We will update the table below when we receive answers from the parties or individual candidates.  If any of the candidates want to get in touch to clarify their current position, we will happily make any corrections requested. Our contact email address can be found here.

WardNamePartyPosition on Winchfield new townPosition on Pyestock
Blackwater and HawleyBLEWETT, Brian Frederick Liberal Democrat Voted in favour Nov 2014?
Blackwater and HawleyCULLEN, Amy LouiseThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Blackwater and HawleyDICKENS, Jane ElizabethThe Conservative Party Candidate Keeping her views to herselfKeeping her views to herself
Blackwater and HawleyFRANCIS, Steven JohnGreen Party OpposeSupport
Blackwater and HawleyGASCOIGNE, MikeUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Crookham EastBUTLER, Helen Rosalind The Conservative Party Candidate Not the right way forwardSupports redevelopment for housing
Crookham EastRADLEY, Edward JamesCommunity Campaign (Hart) Still support new townSupport, but want safeguards on school places, traffic and environment
Crookham EastWILLIAMS, Ruth AnnThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Crookham West and EwshotAMBLER, Simon RoryCommunity Campaign (Hart) Still support new townSupport, but want safeguards on school places, traffic and environment
Crookham West and EwshotMOORS, DawnUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Crookham West and EwshotSIMMONS, ChrisThe Conservative Party Candidate Does not supportDoes not support
Crookham West and EwshotSMYTH, MoiraThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Crookham West and EwshotSPRADBERY, Charles JohnGreen Party OpposeSupport
Fleet CentralBOBETSKY, MaxThe Conservative Party Candidate Opposed when stood for General Election 2015?
Fleet CentralGAWTHORPE, John GrantThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Fleet CentralHOPE, Howling LaudThe Official Monster Raving Loony Party ??
Fleet CentralMAKEPEACE-BROWNE, Wendy LouiseCommunity Campaign (Hart) Still support new townSupport, but want safeguards on school places, traffic and environment
Fleet CentralOWENS, Major DavidUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Fleet EastBUTLER, SamThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Fleet EastDEVONSHIRE, Peter WilliamUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Fleet EastWALTON, Neil ChristopherLiberal Democrat ??
Fleet EastWRIGHT, Jonathan BruceThe Conservative Party Candidate YesYes
Fleet WestBENNISON, JohnCommunity Campaign (Hart) Still support new townSupport, but want safeguards on school places, traffic and environment
Fleet WestBUCKLAND, Lesley RuthThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Fleet WestEINCHCOMB, Paul Stephen WalterLiberal Democrat ??
Fleet WestFORSTER, SteveThe Conservative Party Candidate Voted in favour Nov 2014. Still supports if not enough brownfield available, but only if it comes with proper infrastructureSupports redevelopment for housing, provided it comes with improvements to roads, busses and new schools
Fleet WestRUTTER, KarinUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Hartley WintneyCRAMPTON, AnneThe Conservative Party Candidate Voted against Nov 2014In favour
Hartley WintneyHAMILTON, Ruth StellaUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Hartley WintneyJARMAN, Ruth ElizabethGreen Party OpposeSupport
Hartley WintneyWILLIAMS, Ieuan MonThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Hartley WintneyWOOLFORD, Alan MauriceLiberal Democrat Opposed to new townIn favour
HookIVE, ColinLiberal Democrat Voted in favour Nov 2014. No specific comment in this election.?
HookMORRIS, MikeThe Conservative Party Candidate Voted in favour Nov 2014. Still in favourSupports
HookNABBS, VerdThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
HookREES, DaiUK Independence Party (UKIP) No new town in WinchfieldBrownfield sites as a priority, but no definitive position on Pyestock
OdihamAFFLECK-CRUISE, Amanda JaneThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
OdihamGORDON, Rosalyn JaneLiberal Democrat ??
OdihamKENNETT, John RichardThe Conservative Party Candidate Voted in favour Nov 2014. Now not convinced it is necessaryRedevelopment of Pyestock is very welcome
OdihamOLIVER, KevinUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Yateley EastBURTON, John Peter SimonThe Conservative Party Candidate ??
Yateley EastCOCKARILL, GrahamLiberal Democrat Voted in favour Nov 2014?
Yateley EastGANTLEY, FrankGreen Party OpposeSupport
Yateley EastSTILL, Joyce EdnaThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield
Yateley WestCRISP, GerryLiberal Democrat Voted in favour Nov 2014?
Yateley WestHALL, PeterThe Conservative Party Candidate ??
Yateley WestHOWE, John WilliamUK Independence Party (UKIP) ?Brownfield sites as a priority, but no definitive position on Pyestock
Yateley WestSUTHERLAND, Alistair WilliamThe Labour Party Candidate All Labour candidates in favour of new townSome support Pyestock, but prefer Winchfield

Fleet Town Council seeks to mislead the public

Fleet Town Council Leaflet

Fleet Town Council Leaflet

Fleet Town Council have distributed a leaflet that, in our view, seeks to mislead the public.  The leaflet suggests that a new settlement in Hart would be a “long term sustainable solution to the housing and infrastructure needs” of the district as an “official recommendation”.

We think this is misleading and wrong on many levels:

  • Concreting over the equivalent of 25 football pitches a year is not in any way sustainable, and this approach would lead to another new town being required every 10-15 years and destroy the green spaces that make Hart such a great place to live.
  • The type of housing in a new town estate is exactly the wrong type of housing to meet the needs of our growing elderly population and the needs of our young people struggling to get on the housing ladder
  • A new town will require over £300m of infrastructure funding, with only £50m of developer contributions, and of course will do nothing to address the £78m infrastructure funding deficit across the district.

Surely, it would be much better to follow Ranil’s advice and redevelop our ageing and vacant office blocks in a brownfield solution that will meet the needs of Hart residents as opposed to those wishing to move here from London and deliver infrastructure funding for our existing communities.  Of course, Fleet Town Council offer no evidence at all to support their assertions.

We are of course flattered that they have chosen to make their leaflet in the style of the leaflet we distributed at the end of last year.

Housing Options consultation leaflet

If you would like to make your voice heard and object to the new town idea, we urge you to respond to the Hart District Council consultation about the Local Plan and ask them to think again. We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided. It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

The case for a brownfield solution to Hart’s housing needs

Which would you rather preserve - derelict eyesore or our wildlife?

Which would you rather preserve – derelict eyesore or our wildlife?

As you know, Hart Council has begun a new consultation asking us where we would prefer to build the remaining 2,500 houses we are being asked to build as part of the Local Plan. This has generated some lively debate with some councillors and community groups favouring a new town. Whilst We Hart has a lot of sympathy with the residents of Fleet and Church Crookham, who have suffered from some poor planning decisions over the past years, we aim to show why it would be wrong to consider a new town or urban extension now and make a bad situation even worse.

We have to deliver over 370 houses per year up to 2032.  If these were to be built on green field sites it would mean we would be concreting over the equivalent of 25 football pitches each and every year for 20 years.  This is simply not sustainable, and it is clear something needs to change.

Eminent architects such as Richard Rogers, academics such as Professor Dieter Helm and journalists such as Simon Jenkins have called for our green spaces to be protected and for more building on brownfield land.  The Government is also actively encouraging brownfield development.

The benefits are clear, in that less infrastructure investment is required to support this type of development, urban living makes better use of scarce resources, so is kinder to the environment and town and city dwellers use their cars less and so don’t cause as much congestion.

So, having established the general case for brownfield over green field development, what about the specifics of the proposals before us in Hart?

First, it can be done. We have gone through Hart Council’s data and shown that there are sufficient sites to meet our remaining needs on brownfield site alone, and if we can bring Pyestock into play and Hart are successful in their quest to find even more sites, we will have a surplus of brownfield sites.

Supporters of a new town point to the supposed infrastructure benefits, but we believe this argument is flawed.  There is no doubt that there is a need for more infrastructure investment in our existing towns and villages, as is shown by the current £78m funding deficit.  Even Hart Council acknowledge that new schools would cost £80-100m, but then when you add up the costs of new and improved roads, roundabouts, bridges, sewage works, and railway station, it is clear that a new town will require over £300m of infrastructure spending before you even get to providing new sports and community facilities. But a reasonable expectation of developer contributions is only around £50m.  So, it is clear that a new town, or indeed an urban extension, could not get the infrastructure it needs and more importantly, would not do anything to address the problems in our existing communities .

By contrast, properly designed brownfield redevelopments (not office conversions) would generate developer contributions for local communities and if Hart Council followed Ranil Jayawardena’s advice, they could use compulsory purchase powers to buy up some of these sites and use the profits from development to fund even more local infrastructure.

When you look at travel to work patterns of Hart residents, it is clear that many people work in Fleet, Surrey Heath, Rushmoor and Waverley.  So, residents of a new town will need to travel through Fleet, Church Crookham and Hartley Wintney adding to congestion.  Other workers will travel through Hook to get to work in places like Basingstoke.  Dispersal throughout the district will ease the congestion problem, and brownfield development to the east of Fleet will place workers closer to their jobs and offer greener transport alternatives.

Our housing needs assessment calls for 60-70% of new build properties to be 1 or 2-bedroomed and also calls for over 2,000 units of specialist accommodation for the elderly to be built up to 2031.  A new town or urban extension is likely to continue to build predominantly larger properties at prices of over £500,000 which will no doubt be attractive to those who want to move from London, but will be out of reach of middle income households in Hart and so do nothing for local people.  Well planned development of smaller properties on brownfield sites will do more to help our young people to get on the housing ladder and help older people when they want to down-size to free up their larger properties for growing families.

Of course planning for a new town or urban extension would also open us up to building 3,000 houses for Rushmoor and Surrey Heath.  Whereas a vision and strategy to protect our green lungs in the heart of Hart would offer us some protection.

We also have to challenge the viability of the new town and urban extension plans.  The new town would coalesce our villages into a massive urban sprawl that would effectively become Hartley Winchook.  The proposed urban extensions would add further unwelcome development outside existing settlement boundaries. The professionals who have looked at the new town proposal have said “it would be challenging to plan a compact nuclear settlement on this site”, and of course there are other significant constraints such as lack of mains gas or sewage, flood risk and environmental damage.  All of the new town and urban extension sites have been classed as “not currently developable” by Hart Council.

It is time to make a break from the past mistakes and change to a more sustainable strategy, with a planning horizon of 50 years ahead and realise that more and more housing estates in the countryside are simply not sustainable.  We need to go for dispersal of our housing needs on brownfield sites across the district to build more affordable homes for our young people, create better specialist accommodation for the elderly and generate much needed infrastructure funding for local communities.

We have created a dedicated consultation page and two guides to responding to the consultation that are available on the downloads below. The comments are designed to be cut and pasted into the boxes provided.  It will be very powerful if you could edit the comments into your own words. Please do find time to respond to the consultation and play your part in saving our countryside.

Full version:

Responses to Local Plan Consultation

2 Minute version:

Respond to Local Plan Consultation in 2 minutes

 

Lock, stock and two smoking barrels

lock stock and two smoking barrels

Lock, stock and two smoking barrels

I present without further comment the contents of a letter I sent to Hart District Council yesterday (Friday 20 November 2015). Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Errors, omissions and anomalies in the (Strategic Housing Land Availability Assessment) SHLAA and consultation materials

Dear Messrs Daryl Phillips and Stephen Parker,

It is clear that Hart Council has been very busy, publishing a vast array of new material about the SHLAA and the materials to be used in the forthcoming consultation about Housing Options.  I have burned a considerable amount of midnight oil going through those materials in some detail, and I have identified material errors, omissions and anomalies that give me serious cause for concern that I would like to share with you.  The Excel workbook containing the amalgamation of the SHLAA Master List, the NHB data and the SHLAA detail is attached for reference. These fall into several broad categories:

  • Assessment of brownfield site capacity and delivery
  • Deliverable and developable sites not included in the Developing a Local Plan for Hart paper (DLP) nor the New Homes Sites Booklet (NHB)
  • Sites missing from NHB but in the SHLAA
  • Discrepancies between capacity shown in NHB compared to SHLAA detail
  • Sites shown in detailed assessment but not in master list
  • Sites assessed as “not currently developable”, but have been granted planning permission
  • Range of meanings of “not currently developable”
  • Lack of consideration of the economic aspects of housing options 
  1. Assessment of brownfield site capacity and delivery.

There are a number of components to this:

In Hart News in September, and again at cabinet on 1 October, it was said that brownfield capacity had increased to 1,800 units. Now, this has miraculously fallen by 75% to 450 units on some dubious grounds. First, para 41 of the DLP states correctly that years 6-10 need only “developable” sites to be included, beyond that you can be more vague about sites.  We are already 4 years into the plan period and, according to the land supply calculation based on the current inflated SHMA, we have 5.7 years of land supply.  Yet, you are only selecting sites to be included in your calculations that meet the most onerous criterion of being “deliverable”.  As you know I have two FOI requests outstanding with you, the first is inquiring about the disposition of the 750 brownfield units that we were told were achievable back on November 2014, and the second asking for the analysis to support the 1,800 figure.  It seems to me you have inappropriately applied criteria that are too onerous in order to artificially reduce the potential brownfield capacity.  An example of this would be excluding Bramshill, when everyone knows it will be preferable for this site to undergo some sort of redevelopment to stop the Grade 1 listed building decaying and of course the hideous 1970’s accommodation blocks need replacing too.

You have under-stated the brownfield capacity in the DLP, compared to the assessed capacity in the SHLAA documents. This is shown in the table below:

Parish/Ref Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High) Sum of Brownfield Capacity in Table 1 in DLP doc
Blackwater and Hawley 320 320 300
SHL100 320 320 300
Church Crookham 6 6 8
SHL28 6 6 8
Elvetham Heath 45 45 45
SHL104 45 45 45
Fleet 221 221 83
SHL113 12 12 17
SHL245 8 8 14
SHL320 150 150 20
SHL322 37 37 17
SHL41 6 6 6
SHL42 8 8 9
Grand Total 592 592 436

 

This shows that the capacity shown in the DLP (excluding the 20 units from the sites with planning permission) is some 156 units lower than your own assessments in the SHLAA documents with most of the discrepancy arising from sites SHL320 & 322.  Correcting this would reduce the net requirement by 156 units.

In Figure 2 of the DLP, you assert that 52% of the development completed or where permission has been granted since 2011 is on brownfield sites. Yet at September Council, a question was asked along similar lines and the response was “these figures exclude brownfield sites that require planning permission, because those are not currently split between greenfield and brownfield developments”.  This leads one to conclude either that you have simply made up the figures in the DLP, or you knowingly misled the Council and the public in September.  Which is it?

  1. Deliverable and developable sites not included

[updated with this note]

There’s a large number of deliverable and developable sites that are in the SHLAA but not apparently referred to in the DLP or the NHB.  A list if these is shown in the table below (some of which are in the NHB):

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 320 320
SHL100 320 320
Church Crookham 6 6
SHL28 6 6
Elvetham Heath 45 45
SHL104 45 45
Fleet 25 243 248
SHL113 12 12
SHL245 8 8
SHL275 25 12 17
SHL320 150 150
SHL322 37 37
SHL41 6 6
SHL42 8 8
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Hook 550 550
SHL1&2 550 550
South Warnborough 16 16 16
SHL172 16 16 16
Grand Total 41 1,186 1,191

The land supply document shows a total of 3,878 units built, permitted or deliverable up until 1 April 2015, some 722 below the 4,600 figure you assert in the DLP.  I accept that 340 units from SHL1 & 2 and 10 from SHL69 are included in the land supply.  But the land supply does not include 300 units from Watery Lane.  Netting all of this off, then there are around 5,000 units already accounted for by being completed, permitted or deliverable, which would reduce the current net requirement by ~400 units compared to what you assert in the DLP.

  1. Sites missing from NHB but in the SHLAA

There are 76 units on sites in the SHLAA that are not already on the brownfield list and not strategic sites that do not appear in the NHB.  These are shown in the table below:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Fleet 10 10
SHL69 10 10
Hartley Wintney 6 6
SHL95 6 6
Heckfield 5 5
SHL157 5 5
Mattingley 48 48
SHL160 48 48
Yateley 7 7
SHL18 7 7
Grand Total 76 76

 

This raises the question as to why these sites have not been included in the NHB process either as selected or rejected sites.

 

  1. Discrepancies between capacity in NHB and SHLAA

There are material discrepancies between the site capacities shown in the NHB and those in the SHLAA.  Sometimes the NHB can be above the SHLAA figures and sometimes below.  But overall, adding up all of the sites where the NHB capacity is outside the range of SHLAA lower and upper limits, the NHB shows a lower capacity of some 1,500 units.  This demonstrates that the potential capacity of dispersal sites is being materially under-stated.  These sites are shown in the table in Appendix 1.

 

  1. Sites present in the detail of the SHLAA but not on the master list, and hence not in the NHB, nor mentioned in the DLP.

There are three sites, SHL167, 168 and 169 appear in the detailed assessments of sites, but not on the master list.

  1. Sites shown as “not currently developable” but have in fact been granted planning permission

Sites SHL68 and SHL117 are listed in the detail SHLAA documents as “not currently developable”, but according to the master list of sites have been granted planning permission.

  1. Range of meanings of “not currently developable”

It is clear from the above that the term “not currently developable” is a somewhat elastic phrase that can include sites that are just an administrative stroke of the pen away from deliverability as well as sites that face very significant challenges.  Many sites in the NHB and of course many of the strategic sites face very significant challenges that it is difficult to see how they can be remedied, such as proximity to flood zones, SSSI’s, SINCs, TPOs and the SPA and lack of proximity to existing settlements whereas others are much closer to deliverability.

However, the main materials being circulated for the consultation do not make this distinction clear.

  1. Lack of discussion about economics

The discussion about infrastructure costs in the DLP, with the only mention of costs being the woefully [inadequate] £30m for a new motorway junction – I would think there is little chance of change out of £100m.  But even so this misses out other important infrastructure items like the local road system, new or upgraded railway station, widening of the railway bridges over the local roads, new sewage farm, burying overhead power lines, new schools and new healthcare facilities to name but a few.  Hart currently has a £78m infrastructure funding deficit, Hampshire as a whole £1.9bn and the local NHS is predicted to have a large annual funding deficit.

These issues associated with a new town should be spelled out in detail, and I would think many of the same issues will arise with urban extensions.

It is certainly true that these issues will need to be resolved before the Local Plan can be found sound at examination.

So, what are we to conclude from the above?  First, the discrepancies outlined above, once corrected will make a very material difference to the calculation of how many more houses we need to build on green field sites (if any) and the capacity of each parish to deliver them.  I do not wish to subscribe to conspiracy theories.  However, the sum-total of the above, coupled with the obvious single-minded desire on the part of some members to push through a new town at all costs, leads me to conclude that either the people who created these consultation documents were incompetent or they are by their omission or intent about to mislead the public.   It is also clear that whatever systems and processes you are using to plan, manage, monitor and control the SHLAA are completely inadequate with such large discrepancies between different views of the same data.

It is clear to me that the forthcoming consultation should be postponed until these discrepancies are ironed out.

I would like you to treat this letter as a formal complaint and respond according to LGO guidelines.  I might also add that I will copy this letter to the chairman of the Standards Committee to ask him to set up an investigation and to our Local MP.  You might expect this letter and your response to be presented as evidence in any examination of the Local Plan.

Yours sincerely,

 

cc:           Peter Kern, Chairman of Hart DC Standards Committee

Ranil Jayawardena, MP

 

Appendix 1:

Parish/Ref Sum of NHB Capacity Sum of Site Assessment Capacity (Low) Sum of Site Assessment Capacity (High)
Blackwater and Hawley 15 12 12
SHL21 15 12 12
Bramshill 300 250 250
SHL106 300 250 250
Crondall 112 130 130
SHL159 65 100 100
SHL72 16 18 18
SHL76 31 12 12
Crookham Village 70 100 100
SHL53 70 100 100
Dogmersfield 40 5 10
SHL39 40 5 10
Eversley 91 123 123
SHL127 50 70 70
SHL140 41 53 53
Ewshot 120 187 187
SHL174 63 105 105
SHL355 48 75 75
SHL80 9 7 7
Fleet 706 881 886
SHL102 43 45 45
SHL275 25 12 17
SHL333 500 750 750
SHL50 46 60 60
SHL51 92 14 14
Hartley Wintney 208 287 301
SHL155 117 194 194
SHL216 8 6 6
SHL35 34 3 17
SHL45 25 51 51
SHL91 10 11 11
SHL97 12 10 10
SHL99 2 12 12
Heckfield 169 45 65
SHL109 44 5 5
SHL257 62 20 30
SHL259 63 20 30
Hook 2,090 3,849 3,849
SHL123 13 20 20
SHL3 543 1,000 1,000
SHL4 458 1,800 1,800
SHL5 1,065 1,000 1,000
SHL6 11 29 29
Long Sutton 63 65 65
SHL296 6 5 5
SHL335 34 35 35
SHL336 23 25 25
Mattingley 130 40 60
SHL239 55 20 30
SHL240 75 20 30
Odiham 3,308 2,894 2,904
SHL108 387 160 160
SHL110 2,160 1,900 1,900
SHL138 204 261 261
SHL228 48 75 75
SHL29 10 6 6
SHL328 25 30 30
SHL329 44 30 30
SHL57 47 75 75
SHL59 115 175 175
SHL60 11 12 12
SHL65 36 50 50
SHL67 53 80 80
SHL78 168 40 50
Rotherwick 130 200 200
SHL86 130 200 200
South Warnborough 36 20 25
SHL70 7 5 5
SHL75 29 15 20
Winchfield 119 32 42
SHL114 11 12 12
SHL262 108 20 30
Yateley 9 60 60
SHL13 0 8 8
SHL149 0 10 10
SHL17 0 30 30
SHL303 9 12 12
Grand Total 7,716 9,180 9,269

See more at our consultation page:

link

Community Campaign Hart Council Chairman to discuss brownfield development with Ranil

Hart District Council Offices

Hart District Council Offices

Concrete Community Campaign Hart (CCH) member and chairman of Hart District Council is to meet with our Local MP Ranil Jayawardena to challenge any misunderstandings there might be about the brownfield capacity of Hart District.

CCH are clearly alarmed at Ranil’s intervention on planning matters, especially as Ranil said he was against large-scale, top-down developments generally and he believed (as We Heart Hart believe), that our remaining housing allocation can be met from brownfield sites alone.

CCH have said they are opposed to redeveloping the derelict sites on Fleet Road in Fleet, Hampshire, and instead prefer to build a new town in Winchfield.

The chairman’s statement on this matter is included in the draft minutes of last week’s meeting and reproduced below:

Secondly, I have become aware of the disquiet felt by many members from all political groups about the Planning pronouncements from our MP Ranil Jayawardena. In particular, the assertion that Hart has enough Brownfield sites to build all its housing needs without the need to disturb any significant Greenfield sites outside current settlement boundaries. This is in direct contradiction to the advice we as a council have been given by officers, consultants and members on the Local Plan Steering Group.

In my role as Chairman I have had the pleasure of talking to Ranil on this issue whilst undertaking other civic duties. I therefore took the opportunity to invite him to a private meeting with this Council to explore why such disparate views have come about. His current position is that he would welcome such a meeting. My invitation was made to ensure no misunderstandings remain unchallenged between us as having a fully engaged, briefed and passionate advocate for Hart in Westminster is important for this Council.

I will be working with the Council Leader and Rail’s [sic] office to agree a date that will fit in with his Parliamentary responsibilities. It is therefore likely that the timing of such a meeting will not be a midweek evening so I apologise to working members in advance.

We do hope that Ranil maintains his position and points out to Hart Council members some of our work on brownfield capacity and Ranil also further explains his policy of pushing local councils to be more active.

Separately, the Council Leader expressed some sympathy with the view we should build on brownfield sites alone and even conceded it might be theoretically possible, but fell short of making a commitment to do so. Our questions and the Leader’s answers below:

Question: Do you agree with our local MP who says: “I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in NE Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield…I’m against these developments – indeed, this sort of large-scale top-down volume-led development generally – as I do not believe they are necessary to deliver the housing we need in our area. Looking at Hart District specifically for a moment, as the largest part of the constituency, I believe that the local housing demand can be met on brownfield sites”?

Response: Putting to one side the matter that this is a quotation out of context, Mr. Jayawardena makes three points in this opinion statement. Firstly he says that brownfield should be used before greenfield; as a statement of principle I wholly agree, and always have. However, we are obliged to maintain a five year land supply. As fast as we approve fresh applications, previous consents are being built out; this is a moving target. Unless we can deliver brownfield site planning consents at the rate of that of our ongoing annual housing requirement we cannot deal with this sequentially. Given that we do not have deliverable and developable brownfield sites sufficient for our own Objectively Assessed Housing Needs (OAHN), we are obliged to allocate some sites other than brownfield to achieve the numbers required. Second, he is opposed to a number of specific sites, as am I. We are however compelled to allocate sites which we would prefer not in order to fulfil our OAHN. He states that he believes the OAHN can be met from brownfield sites; this is probably theoretically true, if we compel the use of unavailable sites including those in current active employment use. That is not available to us.

Question: What criteria would you use and how long would a brownfield site need to be vacant, with no sign of redevelopment before the council would consider using Compulsory Purchase Orders (CPOs) to ensure that we can build modern apartments for young professionals who can’t otherwise buy a home in our area?

Response: CPO is not a cheap option. We would be obliged to pay market price for such land, plus the costs of acquisition, and this for a site where the owner has not perceived an opportunity to develop at a profit. It is simply unrealistic that Hart DC could undertake CPO on the scale necessary, and in the timeframes necessary, to persuade an Inspector that such a plan would be deliverable. The Council could not afford to do it. Further, to produce tracts of apartments for young professionals would result in fundamentally unbalanced communities. We need communities which provide for all our residents, including families and older people. Young professional ghettoes are not good planning. In the event that a site would become appropriate for CPO, the site would be considered on its individual merits. You should be aware, however, that the seizure of the assets of others even paying full value is not something this council has seen as desirable, which is why it was not considered as an appropriate means of site assembly should a new settlement proceed.

Question: How many sites would meet those criteria and how many dwellings might they yield?

Response: A site would be considered on its merits at the time.

Ranil emphasises the need for infrastructure alongside housing

Ranil Jayawardena at a brownfield site

Ranil Jayawardena at a brownfield site in Hampshire

Local MP, Ranil Jayawardena has published a new article re-stating his preference for brownfield regeneration and emphasising the need for proper infrastructure to be delivered alongside housing and calling on local councils to take a more active approach.

This is the key passage from his article:

This is an important point. It is clear to me that infrastructure improvements are an absolute necessity for any development – and Government has a role in this part of the equation.

Whether brownfield or greenfield, infrastructure is critical to ensure that these developments not only provides homes for our friends and children, but are taken as opportunities to improve the way of life for existing residents. Whether brownfield or greenfield, development should not come before infrastructure.

I welcome the Hampshire Combined Authority proposal, specifically a ten-year Transport Investment Fund to be used to significantly improve our roads and public transport. This is a good start, but to plan our future, we must consider the past. We should be thinking about the existing infrastructure deficit also and how this can now be mitigated, so that existing residents end up with a better deal.

It is only right that infrastructure is delivered alongside any new development, rather than leaving communities hoping for improvements in the future, when our roads are already jammed and our trains are already crammed.

Ranil also calls on Local Authorities to take a more active role in developing their areas, by actively considering Compulsory Purchase Orders and using development profits to fund additional infrastructure:

There is another way to fund infrastructure, of course. If regeneration is led by local government, through its ownership of the land (whether by private treaty or CPO), the profit that local government makes from the redevelopment can be invested in infrastructure or for the benefit of taxpayers. This is particularly important with brownfield sites, since sites may not be viable – after taking into account a developer’s profit – if they are also required to pay CIL/s106 at the normal level and it would not be good to see large-scale brownfield regeneration without any infrastructure improvements.

Through this vision of active local government, brownfield regeneration genuinely benefits local people, rather than shareholders of a developer, through improved infrastructure and lower Council Tax.

I should probably say that I accept, often, brownfield sites are not in common ownership and, even if they are, the landowner doesn’t wish to develop them. To my mind, however, that is not a reason for brownfield to be put in the ‘too difficult’ pile. Rather, I believe local government has a role to outline how it wishes to comprehensively improve the existing built environment, through purchasing and redeveloping land if not already in its ownership

We wholeheartedly welcome Ranil’s new intervention and we can only hope that Hart District Council are listening. We urge you to sign Ranil’s petition using the button below.

 

Sign Ranil's Petition

 

 

Community Campaign in bitter clash with We Heart Hart

Community Groups in bitter clash over homes Fleet News and Mail 20151028

Community Groups in bitter clash over homes in Hart District, Hampshire

Fleet News and Mail has covered our story where we challenged Community Campaign Hart’s (CCH) plan to decimate the heart of Hart.

Hart District Council takes aim at the Heart of Hart

Community Campaign takes aim at the Heart of Hart

To remind readers, we took CCH to task over their assertions that there was no sustainable alternative to building a new town at Winchfield and their claims about infrastructure and traffic.  In particular, we dispute CCH’s claim that there isn’t enough brownfield capacity, an area where we are backed up by the views of our Local MP, Ranil Jayawardena.

We are delighted that Fleet News and Mail has brought these arguments to a wider audience.  Let’s see how the general public react to the forthcoming Housing Options paper.

A large image of the Fleet News and Mail article can be found here.

This story was also covered in Get Hampshire on November 3 2015: Community Groups in bitter clash over Winchfield homes plan