CPRE concerned about new Government housing targets

CPRE concerned about new Government housing targets.

CPRE concerned about new Government housing targets.

In an article appearing in today’s Fleet News and Mail, the CPRE is concerned about new Government housing targets.

The Fleet N&M has picked up on our article that shows Hart’s housing target will fall to 6,132 new dwellings under new Government proposals. This compares to the Hart’s current Local Plan total of some 10,185. The total outlined in the Strategic Housing Market Assessment (SHMA) of 8,022.

CPRE is concerned about the impact of the new guidelines in southern and east Hampshire and in Basingstoke and Deane. Whilst we share some of this concern, we are delighted about the result for Hart, RUshmoor and Surrey Heath.

We have asked some questions of council that will be tabled at tomorrow’s meeting, so we will find out how Hart plans to respond to these new proposals.

The full Fleet N&M article can be found here.

 

New Government methodology to reduce Hart housing need

Time to celebrate reduction in Hart housing need

New Government methodology reduces Hart housing need

Yesterday, the Government published a consultation (Planning for the Right Homes in the Right Places) on its proposals to simplify and standardise the calculation of housing need. The good news is that Sajid Javid’s new  methodology, if adopted, will result in a significant reduction in Hart housing need. There are also reductions for Rushmoor and Surrey Heath.

Significant reduction in Hart Housing need

Government Housing Need Consultation results in reductions for Hart, Rushmoor and Surrey Heath

Impact on Hart Housing Need

If this proposal was adopted, the full housing requirement for Hart would fall to 6,132 new dwellings. This compares to the Hart’s current Local Plan total of some 10,185 and the total outlined in the Strategic Housing Market Assessment (SHMA) of 8,022. The new target of 6,132 is above the 5,144 we recommended in the recent Local Plan consultation. But, clearly, if the new figure of 6,132 was adopted, we would welcome it.

The Government now calculates housing need on the basis of the most up to date demographic projections. They then add an adjustment for suppressed households and affordable housing. The affordable housing adjustment is based on local house prices compared to local earnings.

This vindicates the stance we have been taking for years now: Hart’s housing target is ridiculous. The current SHMA takes out of date demographic projections and makes lots of spurious and arbitrary adjustments that don’t address the needs of the district. Then Hart Council added a further 2,000 houses to that. This new approach proposed by the Government is much more sensible.

Impact on Rushmoor and Surrey Heath

This is also good news for Rushmoor and Surrey Heath. Rushmoor’s overall housing target reduces by 2,982 houses. Rushmoor has already said it can meet it’s current target, so this leaves it with significant extra capacity.

Surrey Heath’s target reduces by 630 houses. Surrey Heath has said it will endeavour to meet its current housing target, but if it can’t, then Hart and Rushmoor would be expected to make up any shortfall. Previous estimates of their shortfall were around 1,400 houses. These new proposals make any problems Surrey Heath has much easier to solve.

Taken together, these reductions are very welcome and reduce the risk that Hart will be forced to take any overspill from Surrey Heath.

Impact on the Hart Local Plan

There is further good news. If the current Local Plan is more than five years old or if the new Local Plan is not submitted by 31 March 2018, then the new methodology must be used. This means that Hart should start considering this new methodology immediately.

Impact of new housing need methodology on Hart Local Plan

Impact of new methodology on Hart Local Plan

If the new methodology was adopted, then the Hart housing need drops and Hart would need to build far fewer houses. According to the recent Local Plan consultation, a total of 5,594 houses have already been built or planned for as of January 31 2017. This would 600-700 houses left to plan for, maybe a few more to give scope for taking Surrey Heath over spill. In round numbers, let’s assume 1,000 houses left to plan for. Planning for a few more houses than those demanded by the standard method would mean that the Inspector would have to work on the assumption that the Plan was sound.

New Government housing methodology - impact on planning inspectors

New Government housing methodology – impact on planning inspectors

This could be easily made up from brownfield sites in the draft Local Plan. Sun Park (320) and Hartland Park (1,500) would more than meet the remaining need, with plenty of room to spare. This would mean Hartland Park could be built at a slower rate.

The implication of this is that we would need no new settlement. No building at Murrell Green, no new settlement at Winchfield or at Rye Common. Furthermore, Pale Lane (Elevetham Chase) and Cross Farm wouldn’t be required. It remains to be seen whether the inspector will take account of this new methodology to save Netherhouse Copse (Grove Farm) in the current ongoing appeal.

Impact on Neighbourhood plans

In a further piece of good news, the Government proposes that the way housing need in Neighbourhood plans is calculated should be simplified. It says that it should be based on the proportionate population of the Neighbourhood planning area.

New Government housing methodology - Neighbourhood plans

New Government housing methodology – Neighbourhood plans

This is essentially the same proportionate method that we have been advocating for some time. It will finally mean that David Cameron’s promise that local areas should not simply have new housing estates dumped upon them will be met. This proposal will also effectively mean that existing urban areas should become more dense. This is another policy we advocated in the recent consultation.

Note of caution

So far, this is just a consultation and is not yet adopted. There is therefore a risk that developers will seek to water down the proposals or amend them. We have done a quick analysis of the Government spreadsheet and that shows that roughly half of Local Authorities have had their targets increased and roughly half have seen a reduction. Overall, the housing need identified by the Government is about 266,000 houses per annum, in line with previous estimates of overall national requirements. So, in our view, developers don’t have much of an argument – the proposals seem to redistribute the housing targets where they are most needed.

Moreover, there are some potential pitfalls in planning for certain groups such as the elderly and affordable housing in paras 89 & 90. However, this is really about how to get the total to add up, rather than changing the total.

Conclusion

Overall, we think that if these proposals are adopted it is very good news for Hart, Rushmoor and Surrey Heath. The new Hart housing need would be very achievable and would save many of our precious green fields that are under threat.

We would urge you to respond to the Government’s consultation and give it your support.

We also expect the council to set to work immediately to revise the draft Local Plan to take account of these new developments. This should be easy. They are already planning for far more houses than we need, so striking out the controversial green field developments should be a relatively simple task.

 

 

 

 

Challenge the ridiculous housing target in the Local Plan Consultation

Challenge the ridiculous housing target

Challenge the ridiculous housing target in the Local Plan consultation

The main objection to the draft Local Plan is the ridiculous housing target. We believe the Strategic Housing Market Assessment target of 8,022 is too high. Despite that, Hart have added more than 2,000 houses to this target and plans to build 10,185 houses.

This puts massive pressure on the district and puts many greenfield sites such as Murrell Green, Winchfield, Grove Farm (Netherhouse Copse), and Pale Lane (Elvetham Chase) at risk. Moreover, this rate of housebuilding will be carried forward in future planning periods, making it inevitable we end up with unattractive urban sprawl.

We believe the housing target should be a more reasonable 5,144 which will meet the changes driven by demographic change, immigration and deliver social housing for those who cannot afford to rent or buy their own home. The remaining housing target can be met from brownfield sites alone.

The detail of our analysis is shown below. Please object to this ridiculous housing target by downloading the link below and review our suggested comments on the draft Local Plan. Please do make amendments into your own words and submit it to planningpolicy@hart.gov.uk before the deadline of 5pm on 9th June 2017. All of the Council’s consultation documents can be found here.

Response to the Hart Draft Local Plan Consultation

There are several lines of argument:

  • Vastly Over-achieves against Government housing policy
  • Strategic Housing Market Assessment target of 8,022 is too high
  • Hart’s decision to increase the target by 2,000 dwellings to the target is inappropriate

Vastly over-achieves against Government housing policy

The 2012-based government projections of population and number of households, points to a need of around 215,000 dwellings per annum, compared to recent delivery of 130-170,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows that the sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.

It is worth noting that the DCLG forecasts project forwards the recent high level of inward migration to the UK. Government policy and the impact of Brexit is likely to reduce inward migration so, it is likely the 2014-based projections are too high. Moreover, the DCLG forecasts also assume a reduction in average household size.

The 2016 Strategic Housing Market Assessment (SHMA) has arrived at a ‘need’ of some 8,022 new dwellings over the plan period.

For Hart, the raw 2014-based DCLG forecasts, as opposed to the 2012-based forecasts used in the SHMA,  would result in a starting point for housing need of c. 4,473 new houses (see Figure 6 of the SHMA).  Hart’s overall housing requirement as defined in the SHMA is some 79% above the starting point. The ridiculous housing target of 10,185 used in the Local Plan is some 127% above this basic requirement.

If this were applied across the whole country, then we would be allocating land and allowing the building of some 488,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”. Analysis of five other housing needs assessments of planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the starting point projections of around 42%.

There might be some justification if this process had resulted in more house building. But it is clear from a recent House of Lords report that it has not:

Nevertheless, we see the gap between planning permissions and housing completions as a fundamental one in respect of securing increased housing supply. In a climate where over 240,000 homes a year are being granted planning permission, it is a fundamental failure of the development system that over 100,000 fewer homes are actually being built. This situation must be addressed.

We believe that the Government must consider measures to help accelerate the delivery of housing on sites with planning permission, such as permitting the charge of equivalent council tax rates when development has not commenced after a specified period of time, subject to safeguards when there are genuine reasons to prevent the development proceeding.

This is borne out by local experience, where, as of 1 April 2016 there were over 3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.

The unintended consequence of this policy is effectively state-sponsored profiteering on behalf of the major housebuilders. It is plainly ridiculous that the housing target in Hart’s SHMA and the SHMAs of neighbouring areas are massively above the requirement suggested by demographic change, immigration and changes to household size.  Accordingly, the housing target and the Local Plan should be adjusted downwards to more realistic levels.

Strategic Housing Market Assessment results in a ridiculous housing target

Following on from the above, we can now analyse the reasons why the SHMA has arrived at a ridiculous housing target that is too high. We can also arrive at a more realistic figure.

Inappropriate Starting Point

First, the starting point used is the 2012-based DCLG forecasts, or around 5,334 dwellings over the plan period. The starting point should be revised downwards by using the more up to date 2014-based forecasts which would result in a starting point of 4,473 dwellings.

The SHMA then uplifts the starting point in response to market signals to provide more housing for what are termed suppressed households. These are, for instance younger people in the 25-34 age bracket who are still living with their parents and are unable to afford to form their own household. Almost by definition these people cannot afford to rent their own accommodation or buy their own house. The SHMA suggests a 15% uplift on the start-point. Even though some element of household size reduction is included in the DCLG forecasts. We would agree with this and increase the need by 671 units to arrive at a total housing need of 5,144. However, we would insist that these units are delivered as social rented housing. The proposed Hart Development Corporation could be an appropriate vehicle to deliver these homes, or partnerships with local Housing Associations.

Affordable Housing Uplift

The SHMA then makes a further upward adjustment for affordable housing. This is to help those able to afford to rent, but not able to access home ownership. By definition, these people are already housed. It is therefore difficult to see how building more houses will assist these people. If they can afford to rent, then it is very likely that they can afford to service a mortgage, but cannot afford a deposit. The way to help these people is with shared ownership or ‘Help to Buy’ schemes. It is also worth noting that some of these people may be taking an entirely rational decision to rent and not buy because they think property prices are too high and thus represent a poor investment when assessing potential future returns.

The only plausible reason to build more houses to help these people would be that it would lead to a general fall in house prices. This is a false premise as discussed by Ian Mulheirn of Oxford Economics here.

The extent that we do see high house prices as a policy priority in and of themselves (e.g. for wealth distributional reasons), this is not a problem that will be solved by any plausible amount of new supply. Many econometric studies in the UK (see page 43 here for a comparison of results) have concluded that a 1 percent increase in the housing stock per household will only cut prices by at most 2 percent. Consequently, even if we were to add 300k new houses per year (about 150k in excess of household formation, approaching 0.5 percent of current stock), this would only lower prices by about 1 percent per year. This is peanuts in the context of price rises over the past 20 years….

Building many more houses that people want to live in is a dangerous route to go down, as Spain and Ireland can attest. For comparison, Ireland had an estimated surplus of dwellings over households of around 14 percent on the eve of the financial crisis (which among other things proves that households don’t just form because there are vacant houses). This building mania was something like the equivalent, relative to stock, of the UK adding 1 million new dwellings per year from 2002–11. But even this didn’t do anything noticeable to rein in Ireland’s property market during the boom, with prices rising by a fair amount more than the UK’s. A similar story can be told in Spain.

Therefore, the affordable housing need should be seen as the proportion of overall housing need that should be built as ‘affordable’ units. The SHMA adds 504 extra affordable units to the total housing requirement. However, this 504 units represents only 11.2% of the 4,473 raw housing need. Hart’s target is to build 40% affordable housing and recent delivery has averaged just over 20%. If this were to continue and the housing target were revised to start at 4,473, then around 900 affordable homes would be delivered in addition to the 671 social rented units identified above.

Jobs Growth Adjustment

Finally, the SHMA makes a further increase to the housing target to take account of future jobs growth. There are several issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area, a shortfall of 15-30,000, or almost all the projected job growth.

Second, the projection of 1,200 jobs per annum is far more than the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, the SHMA uses a very circular argument to account for the number of jobs. The argument is: the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs.

They then decide we will need to import some extra people and those people will need houses. The SHMA then acknowledges that most of these people will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:

There appears to be an over-supply of lower grade stock with concentrations of dated, larger footprint, stock to the north of the town centre, specifically at Ancells Business Park, which is currently experiencing relatively high levels of vacancy.

Hook office space similarly experiences high vacancy rates and there is strong interest in office to residential conversion.

Commercial agents note that the costs of refurbishing such stock to a good standard attractive to the market typically costs between £50-£60 per sq ft; and that the current over-supply of office accommodation limits investment in refurbishing such stock as low rent levels made such investment unviable.

Clearly, this uplift is not an expression of the ‘need’ for the district, nor is it ‘sustainable development’. The SHMA itself recognises that most of these additional people will, in fact, work outside the district. This is against the sustainability principles of the NPPF.

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs, that someone thinks might be possible to create in Hart. Then those people will add to the strain on Hart’s infrastructure (roads, schools, healthcare), but work outside the district. This is not ‘sustainable development’ on any reasonable interpretation of the phrase. Moreover, those exporting districts should already be planning to house those people.

Accordingly, there should be no jobs growth uplift in the SHMA.

This leaves us with a housing need for Hart of 5,144 made up of 3,573 open market units, 671 social rented units and 900 affordable homes made available through ‘Help-to-Buy’ or shared ownership.

Hart’s decision to increase the target by 2,000 dwellings results in a ridiculous housing target

It follows from this that Hart’s decision to add a further 2,000 units to the SHMA to establish an alleged ‘policy on’ ridiculous housing target of 10,185 is both specious and unnecessary:

  • The needs of both suppressed households and those who can rent, but can’t buy are already met by the revised housing target identified above
  • The addition of a further 2,000 homes would simply import even more people into Hart, most of whom would work outside the district, again contrary to the sustainability principles of the NPPF.
  • There is no evidence that this level of development would lead to falling house prices. Indeed, with residential land priced £4.1m per hectare (SHMA section 9.12) and a density of 30 dph, land prices alone would amount to £133,000 per dwelling. Build costs, S106 contributions and developer profits would see average house prices around £400,000.
  • It is not at all clear why we must build 2,163 extra houses to meet an alleged additional affordable housing need of 865
  • Rushmoor has already said it can meet its share of the over-inflated housing target. Reducing the overall SHMA targets for the whole Housing Market Area (HMA) will release pressure on both Surrey Heath and Rushmoor, such that ‘additional flexibility’ is not required
  • We are currently living in the most benign conditions for housebuilding in living memory. We are experiencing low absolute interest rates and negative real interest rates. The markets are awash with excess capital thanks to Quantitative Easing and the planning regime is very favourable to developers. As the House of Lords report referred to above indicates, planning permission is being granted at a much faster rate than new homes are being built. The only conclusion one can draw from this is that the market cannot absorb many more houses than are being built without a major fall in house prices. The house builders will not build faster as it will damage their profitability. Simply granting permission for more housing through blighting more of our green fields will not impact house prices nor will it lead to more houses being built.

It would be appropriate for the Inspector to express an opinion on the ridiculous housing target in the SHMA and the extra 2,000+ houses. Hart should set out a ranking of sites it wishes to take forward, such that the spatial strategy can be easily adjusted depending upon the final housing target that is agreed.

Independent Expert says Hart housing target is too high

Alan Wenban-Smith of Urban and Regional Policy blasts Hart housing target

Independent expert, Alan Wenban-Smith has reviewed the latest Strategic Housing Market Assessment (SHMA) and concluded that the Hart housing target is way too high.

Regular readers may recall that the same expert examined the previous version of the SHMA and came to similar conclusions.

The crux of his arguments are as follows:

  1. The SHMA uses an inappropriate start-point for analysis. It uses the 2012-based population projections instead of the more up to date 2014-based projections. Making this change would knock around 850 houses off the start point
  2. The adjustments made for so-called market signals and affordable housing are inappropriate.
  3. The massive upwards adjustment for alleged jobs growth would result in loads more people moving to Hart. These people would then work elsewhere which is contrary to the sustainability principles of the National Planning Policy Framework

Taken together, his suggested adjustments would reduce the Hart housing target from around 8,000 to around 4,500. We have already built or planned more then 4,500 houses, so the Local Plan would become irrelevant.

We do not quite agree with all of his conclusions. If it were up to us, we would add some extra social rented housing to help those who cannot afford to even rent their own home.

But nevertheless, it is astonishing that Hart Council has decided to add a further 2,000 houses on to the already inflated SHMA. Hart’s approach is putting unnecessary pressure on our valuable green fields.

We will be compiling our suggested responses to the Local Plan consultation over the next few days. Please do keep checking in as we add further content.

The full report from Alan Wenban-Smith on the Hart housing target can be downloaded from the button below.

Independent Expert critique of Hart SHMA

Hart Cabinet sell us down the river as they plan for 10,000 houses

Hart Cabinet sell us down the river by planning for far more houses than we need

Hart Cabinet plan for houses we don’t need

Hart Cabinet sold us down the river on Thursday night as they voted to plan for 10,000 houses to be built in Hart District in the period up to 2032.

Aside from vote on the paper some other interesting information was disclosed on a number of subjects:

  • Hart Cabinet vote on the 10,000 houses?
  • Do we need a secondary school?
  • Grove Farm (Netherhouse Copse) update
  • Hart Cabinet and Council politics

Hart Cabinet vote on the 10,000 houses?

Well, the short answer is we don’t. Our statement was received without challenge and was described as “informed” by the joint Chief Executive. There really is no answer to the points about double counting, nor the extra 1,200 houses on top of the alleged additional affordable housing requirement. To his credit, Ken Crookes asked some challenging questions. He didn’t really receive satisfactory answers.

The cabinet chose to plan for the extra 2,000 houses on top of those set out in the Strategic Housing Market Assessment (SHMA), even though Ken abstained.

The plan was supported by two cabinet members from Hook. They apparently favour a new settlement that will deliver more houses in Hook Parish. But they vehemently oppose the proposed new development to the west of Hook, that is outside the Thames Valley Heath SPA zone of influence.

There is a risk that Hart will no longer have a five year land supply, now it has agreed an uplift to 10,000 houses. Apparently, officers are working on a new document.

The leader and joint chief executive will now proceed to produce a draft Local Plan. A new consultation will be held on this draft will begin some time in March.

Do we need a new secondary school?

One of the justifications for the new settlement at Murrell Green is that the district needs a new secondary school. You may recall that the council voted on a resolution to include a secondary school in the Local Plan.

However, in his statement to cabinet, the joint chief executive said that although:

Hampshire County Council (HCC) welcome the principle of a new school site, the scale of growth envisaged in the Local Plan is not one that would require the delivery a new school in the planning period.

HCC is responsible for planning school places. But HCC is not responsible for delivering new schools as they will now be delivered as free schools, outside local authority control.

Apparently, Hart has also been offered secondary schools by the developers of Winchfield, West of Hook and Rye Common.

In other words, Hart has acted outside its responsibilities in resolving to deliver a site for a school and the authority responsible for planning school places don’t believe we need a new school. So, we are creating a new settlement to create capacity for houses we don’t need and a school we don’t need either.

Grove Farm (Netherhouse Copse) update

In conversation we found out more about the Grove Farm application. The developer has now appealed this case on the grounds of non-determination.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

To re-cap, the Community Campaign Hart (CCH) chair the planning committee and failed to make a decision on the application at last December’s planning meeting. The council officers has recommended approval.

Hart is going to fight the appeal, probably on the grounds of wishing to maintain the Local Gap between Fleet and Crookham Village.

If Hart does lose its five year land supply, then this will make things difficult at appeal.

Apparently, the risk of losing £1.6m of New Homes Bonus has been mitigated because the indications from Government are that they are no longer going to push through those proposals.

However, there is still a significant risk that Hart will lose this appeal. The expectation is the appeal inquiry will be held in June, with a decision in August.

Hart Cabinet and Council Politics

We have now heard from several sources that one of the reasons Hart Cabinet appears to be so dysfunctional is that the ruling Conservative Party fears a vote of no confidence over the summer. This would entail CCH bidding to oust the Tories, presumably to be replaced by some sort of CCH/Lib Dem coalition. Maybe, the CCH coup is dependent upon the outcome of the Grove Farm appeal.

So, it appears as though we are planning for the extra houses to deliver a new settlement and secondary school we don’t need to appease CCH, who would prefer the new settlement at Winchfield.

It does seem very odd that we are having a new settlement forced upon us by dysfunctional politics.

 

 

Statement to Hart Cabinet

Hart District Council and Hart Cabinet Offices, We Heart Hart. We Love Hart

Statement to Hart Cabinet

The crucial Hart Cabinet meeting to decide the spatial strategy to be incorporated in the forthcoming consultation on the Hart Local Plan will be held tonight at 8pm.

Public participation is allowed and we have been allowed to speak. A copy of our prepared statement is shown below. Please do come along and watch the debate.

Statement to Hart Cabinet 9 February 2017

Thank you for allowing me to speak.

This is an important time for Hart – you are setting out a strategy that will impact the quality of life of Hart residents for many years to come, so it is important you do the best job you can.

Hart Council is in a perilous position and facing the threat of losing around £2m of NHB if the Local Plan is not in place on time and of course the threat of many speculative planning applications. So, it is right that you are risk averse at this time.

However, I would like to use this statement to persuade you to change direction.

I would like you to focus on reducing the housing target of 10,000 by removing the unnecessary uplift of 2,000 extra houses on top of the SHMA target of ~8,000.

The SHMA starts with the ONS population and household projections. It says the “the household projections… are statistically robust and are based on nationally consistent assumptions”. They take account of international migration and migration between districts.

On their own, these projections would point to a need for around 5,300 houses over the planning period. If, however, the SHMA used the more up to date 2014-based figures, the housing need would fall to around 4,500, compared to the 10,000 you are proposing to build.

That’s right, the latest demographic projections point to a need that is less than half of that you are proposing.

However, it is probably right that the housing target should be inflated a little to cater for what is termed suppressed household formation and concealed households.

The SHMA has done this by firstly increasing Hart’s target up to around 6,100 new dwellings to cater for households that are termed ‘can’t rent, can’t buy’ and those who can rent but can’t buy.

Secondly, it then makes a further increase of around 500 affordable homes. This brings the total target to around 6,600.

To my mind 6-6,500 houses would be reasonable overall that would mean we could meet the rest of the target from brownfield sites alone.

To emphasise: The SHMA has met the demographic need and already takes account of suppressed household formation, concealed households and affordable housing.

The SHMA then goes on to add a further 1,400 houses for economic growth, bringing the overall total to 8,000.

This ‘economic growth uplift’ does by definition mean that you are planning for additional inward migration to Hart, people whose needs are supposed to be met elsewhere. Not only that, the SHMA assumes many of these people will also work outside the district and thus put increasing pressure on the creaking transport infrastructure. This is not sustainable development.

Yet, you are now proposing to add a further 2,000 houses to the total to meet extra questionable affordable housing needs.

However, we have already established the SHMA itself has already taken account of the affordable requirement, so this extra 2,000 is double counting.  It will require us concreting over our green fields to meet non-existent housing needs. This is unsustainable over-development.

We wouldn’t need the new Murrell Green settlement if you removed the 2,000 unnecessary houses from the target. I might add the new settlement is entirely unsuitable. It is bordered by the M3 and A30. Criss-crossed by the railway, power lines and a high-pressure gas main. A big chunk of the site is former landfill. Only last year a solar farm was turned down on the grounds it would spoil the view from the Odiham Deer Park and spoil the enjoyment of walkers on the public footpaths. This proposal is far more intrusive than solar panels.

So finally, I urge you, please do the right thing and plan for a sensible housing target. Don’t blight our green fields with so many unnecessary houses. If you really want to help the concealed households, make sure you allocate some of the existing housing target to subsidised social-rented accommodation.

Hart Housing Target increased to 10,000

Hart Council goes through the looking glass as it ups the Hart housing target to 10,000

Through the looking glass as Hart housing target increases to over 10,000

We have gone through the looking glass as the Hart Housing target has been increased to over 10,000.

Hart has now published the document that will be discussed at Cabinet on Thursday 9 February. The main headlines are as follows:

  1. The Hart housing target has been increased to 10,077, with shall we say, questionable justification
  2. The proposed housing allocations are outlined, including a new settlement at Murrell Green

Hart housing target increased

The housing target has been increased to 10,077 as per the table below. This represents a 125% uplift on the 2014-based demographic projections.

ItemItem totalTotal
Housing demand as per 2016 SHMA8,022
Flexibility2,055
Affordable housing rental uplift520
Rural exception site delivery50
Starter homes/shared ownership285
Market housing1,200
Total "Need"10,077
Completions 2011-2016(1,830)
Commitments (to 31 Jan 2017)(3,385)
Windfalls(297)
Remaining to meet need4,565

This is a very questionable increase. The SHMA already factors in a 53% uplift on the ‘natural’ demographic projections, which would give a total requirement of 5,334 dwellings. But if they had used the more up to date 2014-based projections, the start point would fall to 4,473. If we were to use the raw 2014-based figures as our total housing target, we would have already built or permitted the total requirement.

Second, the justification to increase the total to 10,077 is to build 855 extra affordable/starter homes. But the overall increase is set at 2,055 because they don’t expect to build more than 40% affordable properties. This is simply absurd.

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

Third, the SHMA has already made allowance for extra affordable homes (as can be seen above), and then this has already been uplifted for extra so-called jobs growth, which themselves will deliver more affordable homes.  Hart Council seems to be adding uplift on top of uplift in a quite random and arbitrary way. We have already analysed the SHMA here and here.

Fourth, the paper itself says there is no well proven evidence-based formula to uplift the housing target. There is nothing in National Planning Policy Framework (NPPF) that requires the target to be uplifted in a mechanistic way. Nor that the requirements have to be met in full.

No need to increase the Hart Housing Target to meet afordable homes requirement

Hart Affordable housing uplift

In short, the proposed uplift is double counting uplifts that have already been made that we are under no obligation to meet anyway.

If we were to build at this inflated rate, then this would be carried forward and compounded in future demograpgic projections.

Housing Allocations

The paper sets out the proposed allocations to meet this fictitious target, including 1,800 new houses at Murrell Green.

Housing allocations to meet the Hart Housing Target

Hart District housing allocations

No mention is made of Bramshill or Grove Farm (Netherhouse Copse), which are currently under consideration by the COuncil. Indeed we understand that the developers have appealed the Grove Farm application on the grounds of non-determination. Hart were already late in considering the application in December and cancelled the January meeting. Grove Farm is not on the agenda for the February meeting. It is difficult to see how they can defend the appeal.

Conclusions

Hart District Council is in a very perilous position. If it doesn’t get a Local Plan in place soon, it will lose around £2m per year in New Homes Bonus.

So everyone has a strong incentive to get a Local Plan. But by increasing the target to over 10,000 houses, everyone loses for decades to come.

It is difficult to work out the best way forwards. We could either wait until the Regulation 18 Consultation comes out in March and hope that we can influence matters for a better outcome. Alternatively, we can fight now for radical change of both the plan and the people running the process.

Is the Murrell Green new settlement viable?

Murrell Green new settlement proposal

Murrell Green new settlement proposal

We wrote yesterday that the council has prioritised the Murrell Green new settlement as part of the Hart Local Plan. However, there are very real questions about the viability of these proposals.

  • Environmental concerns
  • Infrastructure issues
  • Coalescence of Hartley Wintney and Hook
  • Financial stability of the promoter

Environmental concerns about the Murrell Green new settlement

Part of the site includes Beggars Corner which is the triangular piece of land between the railway and motorway. A proposal for a solar farm on this land was turned down at appeal last year. The main reasons for turning it down were:

  1. Harming the enjoyment of those walking the public footpath across the site. This is shown as a dotted red line on the map
  2. Spoiling the view from the Deer Park at Odiham

Houses are obviously taller than solar panels, and indeed some houses might have solar panels on their roofs. So, how can it be sensible to build houses when solar panels were deemed inappropriate?

Furthermore, a significant part of Beggars Corner used to be landfill, with unknown contents

SHL 167 Landfill details Beggars Corner

SHL 167 Landfill details Beggars Corner, Winchfield, Hart District, Hampshire

It is not appropriate to build houses on this type of land. Nor should it be promoted as green-space for children or dog walking when we don’t know what toxins lie beneath.

It should also be noted that a 110kV electricity transmission line traverses the site as well as a high pressure gas main. Hardly appropriate for housing or recreation.

Gas Main through Murrell Green new settlement Site

Gas Main through Murrell Green Site

The site is also within the Thames Valley SPA 5km zone of influence. There are three Sites of Interest to Nature Conservation (SINC) on the site plus a further SINC just to the west at the River Whitewater.

Finally, there are a number of public footpaths that currently criss-cross the site and they appear to be destoyed by this new proposal.

Infrastructure Issues

The only access to the south of the proposed Murrell Green new settlement is Totters Lane. This is single track in places with a very narrow bridge over the railway. To the north there is the A30 which is already very busy, with choke points at Phoenix Green, Hartley Wintney and the roundabout in Hook. It is difficult to see how these choke points can be alleviated.

Those of us who use Winchfield station know that the car-park is frequently full to capacity and of course, the whole line to London is running over capacity. The idea that either Hook or Winchfield stations can accommodate the extra passengers from thousands more houses is simply laughable.

In addition, the previous strategic assessment of Murrell Green included concerns about:

  1. Healthcare provision – I can speak from personal experience that Whitewater Health that covers Hook and Hartley Wintney is full
  2. Primary school provision
  3. Availability of supermarkets

Coalescence of Hartley Wintney and Hook

The proposed site abuts the south western boundary of Hartley Wintney parish and is close to what are currently quite widely spaced houses.

Hook SHLAA sites in Hart District, Hampshire

Hook SHLAA sites in Hart District, Hampshire

The western side of the Murrell Green new settlement comes within a couple of hundred metres of the new development to the NE of Hook (sites 1, 2 and 3 on the image above). Note that sites 4 and 126 on the map above are not (yet) included in the new settlement proposal.

In essence, we are creating Hartley Winchook.

Financial viability of the promoter

Last year, it came to light that there was a ‘secret plan‘ for a very large settlement that included both Winchfield and Murrell Green. The Murrell Green part of the proposal was promoted by a company called Pearson Strategic Limited.

There are a number of pertinent facts about this company:

  1. It only has one director, James Turner
  2. It was only incorporated in November 2014 and has no revenue
  3. At the time of its last accounts, it has a negative net worth of £3,240
  4. Its only real asset is promotion rights over Totters Farm that has been mortgaged under a fixed and floating charge to Monopro Limited.

One really has to question whether we should be building the Hart Local Plan around a site with such little backing.

Accounts to Pearson Strategic can be found here.

Fixed and Floating charge document can be found here.

Conclusion

Some Hart Councillors seem hellbent on a new settlement regardless of the suitability or viability. In addition, they have not challenged the new Strategic Housing Market Assessment (SHMA) hard enough. If we are sensible about the housing targets and get properly serious about the brownfield opportunities we don’t need a new settlement anywhere in Hart.

Time to make our voice heard again.

 

Breaking News: Hart proposes new settlement at Murrell Green

Murrell Green new settlement proposal

Proposed new settlement at Murrell Green

Hart District Council has proposed a new settlement at Murrell Green as part of its spatial strategy for the Hart Local Plan. This was debated at a meeting of the Local Plan Steering Group last night. The proposal is expected to be agreed at a special Cabinet Meeting to be held on 9 February at 8pm.

The new settlement contains a site for a proposed new secondary school, outlined in yellow in the image above.

We are delighted that the new settlement at Winchfield will not form part of Hart’s strategy.

However, we are disappointed at seeing Murrell Green being put forward as a solution.

[Update] Concerns have been raised about the viability of the proposal [/Update]

Brownfield Capacity

At the council meeting last week, the Leader admitted that Hart now estimate the brownfield capacity at 2,126 dwellings. This excludes the former police college at Bramshill.

HDC Question about brownfield capacity

A realistic assessment of the capacity of Bramshill is around 250 units, bringing the total up to 2,376. However, sadly, Moulsham Lane has been given the go ahead (150 units). This would mean we would have capacity to meet even the over-stated remaining requirement of the old Strategic Housing Market Assessment (SHMA) on brownfield sites alone.

New SHMA overstates the true housing requirement

However, it now appears as though the council has caved in to demands to build even more houses that we don’t need. They have agreed to an increase in our housing allocation to 8,022. On a like for like basis, this leaves us short by 462 units.

This shortfall might well be met by the Netherhouse Copse application (436), which we now understand has been appealed by the developers on the grounds of non-determination. So even with the new SHMA, there is no need for a new settlement at Murrell Green.

At council last week, the leader refused to answer our questions about the reasonableness of building houses to increase inward migration to the district, when many of those people would work outside the district and thus put pressure on infrastructure.

HDC Question about housing numbers

The assumptions I put forward are all in the new SHMA, see here.

We need to challenge this new SHMA and resultant spatial strategy strongly. This will ensure we build the right number and right type of houses to meet local needs, rather than needlessly concrete over our precious green fields.

The full minutes of the council meeting can be found here.

 

 

 

Hart Local Plan: Green fields or fictitious jobs?

 

Should Hart concrete over its green fields for the sake of uncertain jobs forecasts

It is now becoming clear that the forthcoming Hart Local Plan will present us with a choice of concreting our green fields versus building houses for people who live elsewhere and many of them will work outside the district.

We have now had the opportunity to read the new Strategic Housing Market Assessment (SHMA) in more detail, and in particular the detail of the main driver of the housing target uplift: the jobs forecast. We have found:

  1.  The jobs forecasts uplift SHMA calculations increase the overall housing requirement for the Housing Market Area (HMA) that includes Hart, Rushmoor and Surrey Heath by 22% over and above those required by demographics and making allowance for market signals
  2. The National Planning Policy Guidance (NPPG) does not require Hart Local Plan to accommodate extra housing if jobs forecasts are in excess of forecast workforce changes in the area.
  3. The SHMA calls the jobs forecasts ‘uncertain’ and ‘divergent’
  4. If we follow the SHMA, the Hart Local Plan will plan for jobs levels closer to the the extreme high end of the jobs forecasts
  5. That all of the alleged extra jobs will have to be filled by people coming from outside the district, and many of them will work outside the district. This will have a big impact on local infrastructure, particularly roads, rail, schools and healthcare facilities.
  6. Planning for around 900 extra jobs per annum would mean we could meet our remaining housing needs from only brownfield sites
  7. The SHMA says that it would be a more sustainable policy position to plan for increased economic growth to come from productivity improvements, rather than adding lots of lower skilled jobs

This is clearly a ridiculous position, and Hart District Council should follow the advice of Peter Village QC, and consult on the level of employment we wish the Hart Local Plan to accommodate and offer us the choice of planning 900 extra jobs per annum to protect our green fields.

[update]

We would suggest the following approach to the consultation:

Option A, plan for 900 jobs per annum, and around 6,500-7,000 houses, which can be achieved on brownfield (Hartland Village, Bramshill and Sun Park) or

Option B, plan for 1,200 jobs per annum and >8,000 houses for which you will have to give up Grove Farm, and some other area like Murrell Green and/or Pale Lane or West of Hook

We think there would be overwhelming support for Option A, and we would still be planning for 250 extra jobs per annum than the demographics would suggest, so meeting the requirement for positive development.

[/update]

We set out our analysis below.

What does the NPPG say we must do?

As can be seen below, the NPPG simply asks that plan makers ‘consider’ what they should do if the jobs forecasts are in excess of the forecasts for working age population. In particular, it asks for both housing and infrastructure to be considered.

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

Indeed the SHMA itself says that the NPPG does not require plan makers to make any uplift in housing numbers at all.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.50 NPPG does not require housing uplift

SHMA 11.50 NPPG does not require housing uplift

So, whilst the impact on housing and infrastructure should be considered there is no requirement to to actually increase the housing numbers.

What do the jobs forecasts say?

There is a wide range of jobs forecasts ranging from 910 pa (Experian), through 950 pa (Cambridge Econometrics) to the extreme forecast of Oxford Economics at 1,480 per annum.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Section 5 summary range of forecasts

SHMA Section 5 summary range of forecasts

The SHMA acknowledges that the housing numbers required are extremely sensitive to the jobs growth assumptions made

SHMA 11.1 wide spectrum of forecasts

SHMA 11.1 wide spectrum of forecasts

The SHMA calls for us to plan for 1,200 extra jobs per annum which is closer to the extreme high end of the Oxford economics forecast.

What does the SHMA say about the Employment Forecasts?

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

The SHMA says that there is genuine uncertainty about the scale of jobs growth that might be expected and the forecasts are widely spread and divergent.

Where would the people come from and where would they work?

We are told that the extra people to fill these jobs would come from other areas:

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment SHMA 11.56 Population growth from inward migration from other areas

SHMA 11.56 Population growth from inward migration from other areas

If other local authorities are following NPPG, they should already be planning housing for these people. Indeed we have found that many planning authorities are planning for an average of 42% more housing than demographic trends would suggest they need.

But it gets worse, in that the SHMA would lead to many of these inward migrants working outside the district, putting unsustainable strains on the transport network. We already know the rail network is forecast to be running well over planned capacity with no real plan to fix it.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.51 Excess housing supply could lead to extra out commuting

SHMA 11.51 Excess housing supply could lead to extra out commuting

Currently, more than half of Hart’s working population work outside the district and 40% of the HMA’s working population work outside the HMA.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.1 and S11.15 out commuting calculation errors

SHMA Figure 11.1 and S11.15 out commuting calculation errors

What would the Hart Local plan be if we planned for fewer jobs

If we planned for closer to 900 extra jobs per annum, we would need 950 houses per annum in the HMA. Hart would need 305 per annum, leading to an overall housing requirement of 6,405 which would mean we wouldn’t need any more green field sites.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figures 11.13 and 11.14 housing projections for range of job growth

SHMA Figures 11.13 and 11.14 housing projections for range of job growth

Taking account of market signals, the housing requirement for the HMA would be around 1,050 per annum. This would lead to Hart’s overall need being around 7,000. Again, we wouldn’t need any more green field sites to meet this requirement.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

What does the SHMA say about economic growth?

The SHMA says it would be more desirable to achieve economic growth through productivity enhancements and it would be a more sustainable solution.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.55 Better to achieve economic growth through productivity improvement

SHMA 11.55 Better to achieve economic growth through productivity improvement

So, why don’t we go for a more sustainable solution and plan for 900 extra jobs per annum?