Rushmoor responds to criticism by revising evidence base and delaying its Local Plan

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire

While all of our eyes have been on the Hart Consultation about the Local Plan, Rushmoor has also been busy on its own Local Plan.  The most important point is that Rushmoor is revising the SHMA and the Employment Land Review which will:

be beneficial in assisting with a response to a number of comments received through the consultation, which challenged elements of the evidence base, and in particular, raised objection to the fact that the potential shortfall in housing supply in Rushmoor should be accommodated in Hart.

We might add that it was largely We Heart Hart supporters who made these comments – so thank you very much for your contributions.  It does show that reasoned analysis of the evidence base can lead to real change, at least in Rushmoor.

In addition, as well as making reference to the Government’s lower population and household forecasts, Rushmoor say that “all of the three major forecasting houses that produce employment forecasts at local authority level have updated forecasts since those used in the SHMA and the ELR”.  We Heart Hart have strongly challenged the previous jobs forecasts, so we can only hope that these forecasting houses have come up with something more reasonable.

Rushmoor is also revising its land bank database (SHLAA), and this should be available in early 2016.

Interestingly, Rushmoor has also delayed its Local Plan by up to a year in total to cater for these revisions to the evidence base.  Rushmoor’s next consultation, built upon the new evidence base will be in October 2016.

We find it difficult to see how Hart is going to manage to produce a full draft Local Plan by the Summer of this year, when the updated evidence base is not going to be available until the Spring, and it is going to take Rushmoor at least 6 months to process that information and produce the next draft of its Plan.

Rushmoor has also provided a response to Hart’s Housing Options consultation that we will cover in another post.

7 reasons to oppose a new town in Hart

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

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

As the consultation on the Hart District Local Plan draws to a close, it is worth reiterating the main reasons why you should oppose a new town and urban extensions in Hart.

  1. They would open us up to 3,000 extra houses from Surrey Heath and Rushmoor, and we would get the worst of all worlds, a new town, urban extensions and green field dispersal.
  2. The rate of building would then be used against us in the next planning period, so the problems we create today would be compounded into the future.
  3. It would be bad strategy to commit to a new town now, when we know that the housing needs assessment is being revised, and in all likelihood it will be revise down
  4. The proposed new town location is simply not suitable, in that there isn’t enough land to create the nirvana of a self contained new settlement promised by some HDC councillors, and would lead to a giant Hartley Winchook conurbation.
  5. The infrastructure costs are astronomical, and the developer contributions will not meet these costs, thus pushing up council taxes in the future
  6. There is an alternative brownfield solution that will meet the actual needs of Hart residents through providing specialist accommodation for the elderly and affordable starter homes for the young people struggling to get on the housing ladder.
  7. Brownfield development is a more sustainable, greener alternative that will be kinder to the environment and provide infrastructure funding for our existing communities.

If you would like to ask Hart to abandon the new town alternative and create a brownfield solution to our housing needs, 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

 

 

Hartley Wintney residents turn out to oppose Winchfield new town

Hartley Wintney residents turn out to oppose WInchfield new town

Hartley Wintney residents turn out to oppose Winchfield new town

About 150 concerned Hartley Wintney residents came out to hear about Hart Council’s Local Plan consultation this morning at Victoria Hall.  It was very pleasing to see such a large number of people opposing the plans for a new town at Winchfield.

We Heart Hart is very grateful to Hartley Wintney Parish Council for organising the event, and for letting us speak. We had many messages of support and encouragement, before. during and after the meeting.  We only ask that these messages of support are converted into actual votes in the consultation.

We reiterated our main points that:

Hart is being asked to build too many houses. Hart councillors should be thorough in their analysis of the revised Strategic Housing Market Assessment (SHMA), and be robust in challenging the housing numbers and in asking Rushmoor and Surrey Heath to meet their own needs.

Second, there is a brownfield solution to our housing needs, even if we accept the current housing numbers.  We showed how a combination of the brownfield SHLAA sites and the disused offices identified by Stonegate, can be used to meet our remaining housing need in full.

Third, there is a lot of misinformation being spread about the supposed infrastructure benefits of a new town.  We currently have a £78m infrastructure funding deficit which a new town will do nothing to address, and of course, Hart Council have not been able to explain how they will fund the £300m costs of a new town.

Finally, a new town won’t meet the needs of the elderly and won’t deliver starter homes for the young.

Councillor Steve Forster did turn up to speak as well, but was politely asked to sit down again after alienating most of the people in the room.  Some interesting insight and support for We Heart Hart ideas was also given by COunty Councillor David Simpson and district councillor Andrew Renshaw.  Tristram Cary of Winchfield Action Group also spoke, setting out four key reasons to oppose the new town, in line with our thinking.

If you would like to join these Hartley Wintney residents in objecting 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

 

Bravehart answers question posed to We Heart Hart

Bravehart - We Heart Hart Mascot

We Heart Hart’s mascot, Bravehart

As has become the style of Parliamentary questions, I have been posed a question by Steve of Fleet West.  It’s a long and complicated question, but I will do my best to answer it.

The question put to me was:

Question for you. Because Hart already has more SHLAA sites than needed, the duty to cooperate under the localism act required us to use them to deliver neighbouring districts excess needs regardless of whether a new settlement is selected as an option. Some of the SHLAA sites used would inevitably be those in And around Winchfield, but without the master planning and infrastructure provision possible with a planned settlement. And many would be urban extensions causing a burden on existing towns causing further local issues. Do you not think this is the case, and if so why?

First, my understanding is that the “duty to cooperate” is not a “duty to agree” (as we were told by Peter Village QC) and Hart should be robust on two fronts:

  • They should challenge the alleged “need” in the SHMA.  We’ve already established it is based on out of date population forecasts and calls for an “aspirational” level of employment growth that is simply unrealistic.  If these arguments are taken on board, the whole issue of having t meet the needs of neighbouring districts falls away.
  • Hart DC should be robustly challenging Rushmoor in particular who could build more by increasing the density at Wellesley and by releasing some or all of the 96 Ha of employment land they are protecting that it not needed to meet even the inflated employment forecasts.  Rushmoor could even meet some of Surrey Heath’s unmet need.

Second, with or without a new settlement, I simply do not believe the infrastructure numbers add up, and I believe we are being sold a pig in a poke.  £300m costs, versus £50m of developer contribution against an existing £78m infrastructure funding black hole.

Third, it is extremely unlikely that individual Winchfield sites will be picked off (outside those recommended in the Winchfield Neighbourhood Plan) because they simply do not meet the criteria as suitable places for development.  Let’s run through some of the constraints identified in the official evidence base:

SHL 83: The area of the site which is a SINC should not be developed and should be protected from any development, as should those other SINCs nearby. A contribution towards SPA mitigation would be required. Policy would need to be changed for this development to be permitted by way of allocating a settlement boundary to Winchfield which includes this site (however this seems unlikely given that the site is on the other side of the M3 from the rest of Winchfield. The constraint relating to the location, remote from settlements with a boundary seems unlikely to be overcome therefore the site may not be considered suitable or achievable in future.

SHL 133: The fact that the site does not relate to any existing settlement boundary cannot be overcome. Policy would need to be changed for development to be permitted at this location by way of a broader strategic allocation.

SHL182: Site is not related to any settlement; Southern boundary edge within flood zones 2 and 3. Mostly high, but partly medium potential likelihood of groundwater flooding.

SHL183: Site is not related to any settlement; North eastern corner in flood zone 2 and 3; High potential likelihood of groundwater flooding.

SHL184: Site is not related to any settlement; Mostly medium, but some high potential likelihood of surface water flooding.

And then of course we have the Adams Hendry assessment of the combined strategic site:

  • “The road infrastructure in the Winchfield area reflects the areas rural character and has limited capacity for additional traffic. Therefore a key infrastructure issue for developing any significant level of housing at Winchfield is how the road infrastructure can be upgraded to meet the projected levels of demand and how traffic to/from the new development would access the M3 Motorway.”
  • “There are a number of significant nature conservation features and designations either adjacent or in close proximity to the site.
  • “Some part of the site are subject to area based TPOs, particularly to the north of the site, near to Winchfield House”.
  • “The Hampshire Minerals and Waste Plan Policies Map indicates that parts of the site contain areas subject to minerals safeguarding for sharp sand and gravel… The extent to which this might constrain development will need to be assessed, including through engagement with Hampshire County Council.”
  • “The two halves of the site differ in landscape terms with the western half being characterised by the mosaic pattern of generally medium-sized fields interspersed by numerous wooded copses and heavily wooded field boundaries… Most of this part of the site could reasonable be characterised as attractive rolling countryside… The potential for new development within this area to negatively impact on landscape character is considered to be significant.”
  • “The eastern half of the site is much more open, except for the southern portion near to the Basingstoke Canal… The countryside in this area is less attractive than the western part of the site, although its lack of current development and open nature means that significant development in this area has the potential to cause considerable harm to landscape character.
  • “It is possible that the site contains some ʻbest and most versatileʼ (BMV) agricultural land, but this would need to be confirmed through a survey.”
  • “There are a variety of Listed Buildings within and adjacent to the site… The most significant heritage features impacting on the site are as follows:-
    • The Basingstoke Canal Conservation Area… there is considered to be a risk that development towards the south of the site will negatively impact on the setting of the Canal;
    • Dogmersfield Park (Historic Park and Garden)
    • Winchfield House (Grade II*) and its extensive grounds
    • St Mary’s Winchfield if a Listed Norman Church (Grade I)… it is considered that development close to the southeast boundary could have a negative impact on the currently very rural and sparsely developed setting of the church.”
  • “Significant parts of the site are subject to the risk of groundwater flooding at the surface”.
  • “The nature of the site, split, with substantial areas of farmland, as well as Winchfield Station between the two halves is considered to significantly influence how a new settlement could be planned. It would be challenging to plan a compact nuclear settlement on this site and the shape of the site lends itself more to a linear or ʻlinked polycentricʼ approach.”
  • “Development at the north of the site risks leading to settlement coalescence with Hartley Wintney”.
  • Overhead power lines traverse the site and may represent a constraint”.
  • “The extent to which environmental noise from the motorway and railway impacts on the site should be ascertained”.

So, it seems that Winchfield is a bad location for a new settlement, and an even worse location for individual developments.  I would hope we can avoid urban extensions on green fields too, and would like to see significant regeneration of existing towns and investment in infrastructure in those places.

 

How developers have gained a stranglehold over Local Plans

The new age of crony capitalism

The new age of crony capitalism has gained a hold over our planning system

The latest 2012-based government projections of population and the number of households points to a need of around 215,000 dwellings per annum, compared to recent delivery of around 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 housebuilders 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.

By way of example, in Hart, the only consultees outside of the council in the work to produce the Strategic Housing Market Assessment (SHMA) were housebuilders, their representatives and registered providers. The resulting objectively assessed “need” was nearly 50% above the starting point identified by the DCLG’s 2011-based population projections. A series of adjustments were made to the raw forecasts to take account of inward migration to the area, average household size and a near doubling of the historic job creation rate. Many of these adjustments have been shown to be erroneous by the release of the DCLG 2012-based population forecasts that are much lower than those identified in the needs assessment.

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 population projections of around 42%.

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”. An FOI request has been made 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 monitoring the results of housing needs assessments on a national basis.

As a group of local residents, we looked at the housing needs assessment for Hart and came to the conclusion that many of adjustments and the resulting “need” were inappropriate and challenged the Council. But, as we were lay people and not planning “experts” our views fell on deaf ears. So, we decided to seek the opinion of professional planning consultants to provide an independent challenge to the objectively assessed need. Our experience indicates that many planning consultants are reluctant to get involved in challenging these assessments because they get most of their work from developers and do not wish to bite the hand that feeds them. We approached a number of planning consultants and they either did not reply to us, were conflicted or said they normally act for developers and would be unable to help. Eventually, we found Alan Wenban-Smith.

Once a Local Plan gets to the stage of being examined by the Planning Inspector, the situation gets worse. Because housing needs assessments are usually produced for a combination of planning authorities but Local Plans are examined at the planning authority level, the actual housing need numbers are effectively unchallengeable. The examination focuses on the process for arriving at the housing need and the actual content is immune from challenge. Residents and environmental interests are being crowded out of inspections by the expensive hordes of lawyers, agents and consultants hired by builders and landowners who share an interest in a narrow discussion focused on achieving the maximum possible increase in estimated housing needs.

In effect, the whole process of assessing housing need through to inspecting the resulting Local Plans has been hijacked by the development industry and their narrow interests. This is in direct contravention of the NPPF which states that local people should be empowered to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of their area.

The consequence of this is that local planning authorities are being bounced into allocating green field sites for development because they are easier to develop than brownfield sites. This will result in an over-supply of land and lead to land-banking by the developers, who will only build at a rate consistent with maximising their profits. If they supplied new housing at a rate that meant house prices fell, they would immediately reduce output because their business model and in particular the price they pay for land is predicated on steadily increasing house prices. So, in effect we are being asked to allocate too much of our most valuable green field land for housing, but will not actually increase the supply of housing to meet the needs of our neighbourhoods and we leave acres of vacant and derelict brownfield sites.

We need to take action now to remove the stranglehold of developers have on this process, put more power back in the hands of local people and take further measures to mandate the development of brownfield sites and protect our countryside. This might involve increasing the powers of local authorities to compulsorily purchase derelict sites and use the profits to invest in our creaking infrastructure.

We must stiffen the resolve of our local representatives to resist the self-interest of developers and work instead for their electorate.  We must also stand up and fight for brownfield only development to protect our countryside from urbanisation. We must vote against a new town.

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

 

Impact of a new town on Fleet and Church Crookham

Fleet and Church Crookham

Impact of new town on Fleet and Church Crookham

I have a great deal of sympathy for residents of Fleet and Church Crookham who have suffered a great deal of development in recent years with insufficient investment in infrastructure.  However, a new town in Winchfield, Hook and Hartley Wintney parishes is not the panacea for Fleet residents that that many of the Hart Councillors would have you believe.
There will be negative impacts in 4 main ways:

  • Starvation of infrastructure funding
  • Extra traffic and congestion
  • Lack of affordable homes
  • Destruction of amenity space

Infrastructure Funding

Hart Council currently has a £78m infrastructure funding deficit, much of it in Fleet, Church Crookham and Hook. This does not include healthcare where there is a forecast £47m funding deficit in five years time.  A new town will need about £300m of infrastructure spending to make it work, but a realistic assessment of developer contributions is £40-50m.  This leaves a further gap of ~£250m.  There are already complaints about long waiting lists at doctors and lack of other amenities.  It is clear that a new town will be under-funded with consequent impact on other parts of Hart District, where there will be no spare money to address the deficit that already exists in all areas of Hart including Fleet and Church Crookham.

 

Congestion

Where Hart Residents Work

Where Hart Residents Work, SHMA Figure 13

Let’s have a look at where Hart residents work, using the evidence of the Strategic Housing Market Assessment (SHMA).

A bit less than half of them work in Hart – 45%. So of the 12,500 new people in a new town, 45% of those of working age will work in Hart. The biggest employment centres are in Fleet and Hook. So a significant proportion of the new town workers will go to work in Fleet. They are not all going to work in a new supermarket in the new town.

A significant proportion will also work in Rushmoor (Farnborough and Aldershot), Surrey Heath (Camberley) and Waverley (Farnham) – some 18% in total.

The most obvious travel to work route for many of these people will be along Pale Lane, through Elvetham Heath/Fleet or along Chatter Alley, through Dogmersfield, Crookham Village and Church Crookham.  But these roads are narrow and a difficult to upgrade due to bridge constraints, so maybe a new road out of the new town on to Hitches Lane will be required.

A big portion – 6.2%, will use the train to go up to London from a station that is already full, on a line that is operating at or above design capacity.

Another group will go to Hook directly, or through Hook and/or Hartley Wintney to get to Reading or Bracknell adding to existing peak time congestion on the A30.

Pretending a new town will have no impact on congestion in Fleet and the Crookhams is plainly wrong.

Surely much better and more sustainable to direct housing development to the east of Fleet at Ancells Farm, Bramshott Farm and Pyestock (some of them brownfield sites) with a cycle route to Fleet station and a cycle route to the Cody Tech centre or the Farnborough airport complex.

Affordable Housing

 

Vacant Office Admiral House, Harlington Way, Fleet, Hart District, Hampshire

Admiral House, Harlington Way, Fleet, Hart District, Hampshire

As of 26/11/15, the cheapest 1-bed and 2-bed new homes available within 1 mile of Fleet are available at prices of £215,000 and £235,000 (Rightmove). Median household incomes for Hart are £40,200 per Figure 4.8 of the SHMA. This means that the cheapest new homes are between 5.3 and 5.8 times median incomes and out of reach for the average household, so something should be done.

The SHMA calls for 60-70% of new build to be 1 and 2-bed properties across the Housing Market Area.  The developers are going to want to do what they always do, that is to build 3-5 bedroom detached houses in the new town which will be no doubt attractive to those moving from London, but will do nothing to meet the needs of ordinary people living in Hart.

Surely, it would be better to build smaller, starter properties on brownfield sites such as Ancells Farm, Fleet Road, Harlington Way in Fleet and Bartley Wood in Hook to give younger people a more affordable first step on the housing ladder.  This iwll do far more to meet the actual need outlined in the SHMA, and be more sustainable for our environment.

Destruction of amenity space

The Heart of Hart, the area around Winchfield, is used as an amenity area for walking, cycling, watching wildlife and other recreation. Concreting it over and joining together Hartley Wintney, Winchfield and Hook into a giant Hartley Winchook conurbation will lead to lack of amenity for everyone.  Hart Council is yet to report on the consultation it ran earlier this year on how we value our amenity space.

If you are concerned about the impact of a new town, we have created 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

Independent Expert says we are being asked to build too many houses

Time to celebrate we don't need so many houses

Time to celebrate: Hart, Rushmoor and Surrey Heath don’t need so many houses

An independent expert, Alan Wenban-Smith has taken a look at our housing needs assessment and concluded that Hart District is being asked to build too many houses.  He says that the overall house-building rate for the combined area of Hart, Surrey Heath and Rushmoor should more than halve from 1,180 dwellings per annum (dpa) to 558 dpa, and that for Hart should fall from 370 to 268dpa.  This would reduce the overall housing need for the housing market area from 23,600 to 11,160 and that for Hart from 7,500 to around 5,500.  This calls into question the validity of carrying out a new “Housing Options” consultation now when there is serious doubt about the accuracy of the housing numbers we need to deliver. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

This is very good news in that if this analysis is upheld at inspection it should lead to the following conclusions:

  • We can meet all of our remaining housing need from brownfield sites alone.
  • We definitely would not need a new town in Winchfield or anywhere in Hart, nor would we need any urban extensions.
  • The risk of needing to build 3,000 houses to cater for the unmet needs of Surrey Heath and Rushmoor should fall away.
  • There may be an opportunity to ask Surrey Heath and Rushmoor to build more houses for Hart, so we could keep our beautiful countryside.

Mr Wenban-Smith’s full report was commissioned by We Heart Hart and Winchfield Action Group can be downloaded here:

Critique of Hart SHMA

Critique of the Hart, Rushmoor and Surrey Heath SHMA by Alan Wenban-Smith

The summary of his argument, together with the implications is discussed below:

The starting point for assessing housing need in Hart used the 2011-based population projections from the Government and then made a series of changes to extend those projections out to 2031; adjust for higher inward migration estimates and for smaller average household size.  These 2011-based projections have been superseded by more recent 2012-based figures that already make projections to 2031 and already include the adjustments made above.  The effect of this is to reduce the start-point considerably.

Hart has already commissioned a review of the Strategic Housing Market Assessment (SHMA) to take account of these latest Government figures and so should include this reduction.  We should know the results of this work early in 2016.  However, this does call into question the validity of conducting a new consultation now when the numbers are subject to such a large degree of change.

Then Mr Wenban-Smith challenges the jobs forecasts in the SHMA, concluding that the level of jobs growth we achieved in the period 1998-2008 would be a “good result” and the increases in jobs and houses needed to support economic growth should be reduced.

Finally, he then goes on to say that the level of house need shown in the SHMA cannot be delivered by the market.  If the amount of land required to meet the need is allocated by the council, then this will lead to housebuilders cherry picking the best sites and building at a rate that gives them most profit,  not at the rate required to meet the needs. So, he concludes that the level of housing proposed is unsustainable, and therefore contrary to the NPPF and should be reduced.  This is in-line with current guidance about SHMAs from the Planning Advisory service that says:

Based on these reasons, we conclude that the OAN should be principally understood as a measure of future demand rather than aspiration. Accordingly we propose a working definition as follows:

‘The housing that households are willing and able to buy or rent, either from their own resources or with assistance from the State’.

Housing targets systematically over-stating housing need

Is this what we want Hart to turn into?

Is this what we want our countryside to turn into?

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

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

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

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

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

 

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

 

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

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

The SHMAs on which this analysis is based are:

Hart, Rushmoor and Surrey Heath, here.

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

East Hampshire, here.

Waverley, here.

Berkshire, here.

Oxfordshire, here.

 

 

Fog descends on the Hart Local Plan

Fog descends on Hart Local Plan

Fog descends on Hart Local Plan

A number of new developments are emerging on the Hart Local Plan, that show that the overall process is confused and murky.

First, we understand that a new Housing Options paper is being produced that will go to a special meeting of Hart Council Cabinet on 18 November.  This paper will then be offered for consultation, although the consultation period is not clear.  Usually, six weeks are allowed for consultation, but there is some suggestion that this period will be reduced.

Second, it has emerged that the Strategic Housing Market Assessment (SHMA) is being revisited to take account of changes in the population and household forecasts.  We hope that this work will also take the opportunity to take a fresh look at the outlandish jobs forecasts in the current version of the SHMA.  We believe that this work should result in an overall reduction in the housing allocation for Hart and the rest of the housing market area that includes Surrey Heath and Rushmoor.  This would be good news and should remove the threat of Surrey Heath and Rushmoor asking Hart to build 3,000 houses for them.  It is understood that this work will be completed early in the New Year.

Third, Hart District Council is embarking upon a process to identify additional brownfield sites across the district by consulting with town and parish councils.  It is unclear how long this process will take, but it is fairly clear it will not be complete by the time the Housing Options paper is due to be completed.  The council has still not committed to creating a proper register of brownfield sites across the district.

Finally, Rushmoor are still working on the results of the consultation they ran over the summer and are planning to publish a revised Local Plan for consultation early in the New Year, presumably taking account of the revised SHMA.

Pulling all of this together, it appears we are going to be consulted again on Housing Options which is to be welcomed, but the number of houses we need to accommodate will not take account of the latest thinking in the revised SHMA, nor Rushmoor’s revised plan nor will it take account of the total brownfield capacity in the district.  It also seems odd that the council is seeking to force through a new consultation on a compressed timescale in the run up to Christmas, which is a time most residents will be focused on other things.  All in all, a very murky process.