Why is it important for Hart residents to oppose the Rushmoor Local Plan?

 

Example of Urban Sprawl

Example of Urban Sprawl

We have received some feedback questioning why Hart District residents should contribute to Rushmoor Borough Council’s consultation on its Draft Local Plan.

The main reasons are:

  1. Help fend off the extra 1,600 houses Rushmoor wants Hart to build for them and avoid urban sprawl like that shown above.
  2. Challenge the Strategic Housing Market Assessment (SHMA) that has led to the combined Hart, Surrey Heath and Rushmoor housing requirement being set so high.  If we are successful in this, then Surrey Heath and Rushmoor don’t need to foist houses on Hart and the whole need for a new town at Winchfield or anywhere else goes away
  3. Push for more of the housing requirement to be built on the 196 hectares of surplus brownfield employment land.
  4. Point out the fundamental flaw of the combined £158m infrastructure funding deficit across Rushmoor and Hart (and £1.9bn funding deficit across Hampshire) that will mean we will get all of the houses but none of the infrastructure spending we need to build the healthcare facilities, expand rail capacity, fix broken roads and build the schools we need.

Please download the pre-prepared feedback forms, fill in your details and send off to plan@rushmoor.gov.uk.  The consultation closes on 20 July 2015.

 

Rushmoor Local Plan Response Form

 

Additional Response to Rushmoor Local Plan

link link

Massive surplus of brownfield employment land but Rushmoor wants Hart to concrete over green fields

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

The Employment Land Review (ELR) shows there is a massive surplus of around 600K sq m employment space occupying around 195 Ha of land across the combined area of Hart District, Surrey Heath and Rushmoor Boroughs. Yet, Rushmoor is seeking to protect 96 hectares of this land whilst at the same time trying to force Hart to build 1,600 houses for them on our beautiful green fields.

 Employment Space (sq m)
Overall Requirement to 2032 (a)266,368
Current vacant space (b)527,840
Sites with planning permission (c)338,187
Surplus in 2032 (b+c-a)599,659

If you would like to ask Rushmoor to revise its draft local plan, please download our pre-prepared response form and send it to plan@rushmoor.gov.uk.

 

Rushmoor Local Plan Response Form

 

The analysis to support the conclusion is shown below.  We posted earlier that the ELR is based on the same flawed jobs forecasts as the housing market assessment that predict a near doubling of the job creation rate we achieved in the period 1998-2012.  However, even if you accept these flawed forecasts and the unnecessary increase in housing it will lead to, the requirement for employment land in the combined economic area is 266K sq m using Rushmoor’s preferred Scenario 3.

Employment Land Requirements for Hart, Surrey Heath and Rushmoor

Employment Land Requirements for Hart, Surrey Heath and Rushmoor

However, as of December 2014, over 527K sq m of employment floorspace was lying vacant.

Vacant Employment Space in Hart Surrey Heath and Rushmoor

Vacant Employment Space in Hart Surrey Heath and Rushmoor

Moreover, there is a glut of employment space all across neighbouring districts with very high levels of vacant office space (note that there are also high vacancy rates on industrial land):

Office vacancy rates in neighbouring districts

Office vacancy rates in neighbouring districts

In addition to the vacant units shown above, there is currently 388K sq m of floorspace on 110 Ha of land that currently has planning permission but is not yet being built:

Unimplemented planning permission in Hart Surrey Heath and Rushmoor

Unimplemented planning permission in Hart Surrey Heath and Rushmoor

Drawing this together, there is a need for 266,000 sq m of space to meet the inflated employment forecasts, there’s currently 527,000 sq m lying vacant, with a further 338,000 sq m with planning permission, but not yet built.  This would leave a surplus of nearly 600,000 sq m of employment space that might occupy around 195 Ha of land, using the same ratio of employment space to land use as the existing planning permissions.

It is clearly ridiculous for all of this land to be protected when even if say 100 Ha is made available, at 100 dwellings per hectare there could be room for 10,000 dwellings, a very large proportion of the overall 24,413 houses that have been allocated to Hart, Surrey Heath and Rushmoor.

Please help Hart fend off an extra 1,600 houses from Rushmoor

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

Rushmoor Borough Council has published a draft Local Plan where it proposes to build only 8,200 of its assessed need of 9,822 houses over the plan period.  It is clear that Rushmoor is seeking to offload the remaining 1,622 houses on to Hart District.

We need to oppose this move and We Heart Heart have produced some materials to help you do this easily.  Our voice will have greater weight if we can get more Hart residents to comment on Rushmoor’s plan than Rushmoor residents. Please follow the simple process below:

  1. Download the Local Plan response form from the link below.
  2. On page 3, fill in your name and contact details and type your name and date in the boxes at the bottom of the page.
  3. Review the comments made and feel free to add, amend or delete as you see fit.
  4. Save the document, attach it to an email and send to plan@rushmoor.gov.uk
  5. Share a link to this page to all your friends and family as well as any sports clubs or community groups you belong to via word of mouth, email, Facebook and Twitter and ask them to put in a response and share this page again.
  6. If you have not already done so, please sign and share our petition too.
Rushmoor Local Plan Response Form

A summary of the arguments we are putting forwards is outlined below.

Slippery slope to taking more housing than the other districts

The proposal to take an additional 1,622 houses from Rushmoor puts us on the slippery slope to accepting a further 1,400 houses from Surrey Heath such that Hart District ends up having to build the most houses in the Housing Market Area.

 

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

 

This will impact all of our districts including Blackwater and Hawley; Bramshill;  Church Crookham; Crondall; Crookham Village; Dogmersfield; Elvetham Heath; Eversley; Ewshot; Fleet; Greywell; Hartley Wintney; Heckfield; Hook; Mattingley; North Warnborough; Odiham; Rotherwick; South Warnborough; Winchfield; and Yateley adding additional pressure to an already difficult situation and make it more likely we have to accept both a new town and urban extensions on our beautiful green fields and countryside.

Hart and the rest of Housing Market Area are being asked to build too many houses

The whole Housing Market Area (HMA) should reduce the assessed need by 7,800 units which would reduce the pressure on Hart directly and remove the need for Surrey Heath and Rushmoor to ask us to build >3,000 houses for them. This is discussed in more detail here.

Rushmoor isn’t making best use of its brownfield sites

This is discussed in more detail here and here. As can be seen, if Rushmoor gets more creative with Wellesley and plans to build on the sites it has already identified, there is potential capacity for over 30,000 dwellings, more than three times its (overblown) assessed need.   It surely cannot be too much to expect them to find the 1,600 houses they say they can’t build out of this wealth of opportunity.  Rushmoor Borough Council should re-visit its planned densities and seek to meet all of its assessed need within in its own boundaries.  It could then make some sites available for neighbouring rural districts in line with a recent survey of Hampshire residents seeking to protect rural areas.  Neighbouring districts could be approached to provide SANG capacity if required.  Rushmoor should also take a closer look at all the vacant sites in the district and seek to convert them to residential use.

Rushmoor’s Employment Land Review is overblown and seeks to protect more employment land than is necessary.

This is discussed here.  It is also clear that past forecasts got it wrong as evidenced by the large number of vacant office blocks and empty shops across Hart District.  If the ELR was reduced to more sensible levels they could free up more land for housing.

Indeed, even if you accept the overblown employment forecasts, there will be a surplus of nearly 600K sq m of employment space at the end of the plan period, covering around 195 Ha.  Yet Rushmoor seeking to protect 96 Ha of land whilst asking Hart to build 1,600 houses on green fields.

Rushmoor’s infrastructure plans are not credible

We posted here that Hampshire as a whole has a £1.9bn infrastructure funding deficit, with Rushmoor’s share of that being £80m.  Rushmoor makes no mention of this deficit in its draft Local Plan.  Hart’s own numbers show an infrastructure deficit of £78m.  All of these numbers are probably an under-statement given they were all produced before the scale of development now proposed was known.  This is in contravention of NPPF para 177 that says there must be a “reasonable prospect” of delivering the required infrastructure alongside housing:

“It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan”

Finally, they don’t even attempt to quantify the extra infrastructure Hart would need to build the extra 1,600 houses nor do they make any offer to fund any of that extra cost.

Rushmoor not planning to meet the needs of the ageing population

Figure 10.15 of the SHMA sets out the need for specialist housing and registered care places for the HMA and Rushmoor.  This states Rushmoor must build 710 sheltered and extra care units as well as provide an extra 600 registered care places. Their draft Local Plan makes no mention of the extra registered care places and sets no target for the sheltered and extra care units.  This is in contravention of NPPF para 50 which states:

“local planning authorities should…plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes)”

Therefore the Rushmoor draft Local Plan runs the risk of being found unsound and should be revised.

 

In conclusion, the Rushmoor draft Local Plan contains many serious flaws and needs to be revised.

Link

 

Hart Council rolls over and starts to plan for an extra 1,600 houses from Rushmoor

Is this what we want Hart to turn into?

Do we want Hart District to turn into an urban sprawl?

We Heart Hart understands that at the Local Plan Steering Group last week councillors were told that they will have to start planning for an extra 1,600 houses from Rushmoor.  We have previously warned that by planning for a new town, Hart was creating capacity that would force it to take the unmet needs of Surrey Heath and Rushmoor. Indeed the advice from Peter Village QC was that Hart should pursue the duty to cooperate discussions in a “robust and inquisitive manner”.

This would take Hart’s target to 2032 up to 9,134, up from the current (in our view overblown) target of 7,534.  This is simply wasting the good work that has identified additional brownfield capacity in the district.

However, Hart Council’s actions are going much further than the advice they received from the Planning Inspector as recently as March 2015:

“Tactically, Hart should show to an inspector that it acknowledges the housing problem, and accept that it is likely to have to take an element of unmet need now. This would show an inspector that Hart is being reasonable in the circumstances. In practice this could mean taking an element of Rushmoor’s need now, but dealing with further shortfalls in Rushmoor and Surrey Heath through an early review once there is more certainty over what those authorities can deliver. Hart would need to quantify the amount of unmet need it is agreeing to take in its plan. It would also need to justify why it’s not taking all the unmet need.”

So, far from taking “an element” of Rushmoor’s need now, they are proposing to plan to take the whole lot.  Of course there are no reports yet of how they are going to close the existing £78m funding gap, let alone how to fund the extra infrastructure required to support the extra 1,600 houses we have to build for Rushmoor.

The whole reason why we are being put in this position is that the combined housing market area of Hart and Rushmoor and Surrey Heath Boroughs is being asked to build too many houses because the Strategic Housing Market Assessment (SHMA) is based on some dodgy forecasts.  If the SHMA was brought down to more realistic levels, then neither Rushmoor nor Surrey Heath would have a shortfall.

We need to challenge Rushmoor’s plan now.  We have created a template letter, together with an up to date distribution list of all of the Hart District Councillors and it is available for download below.  Please download it, and all you need to do is cut and past the contents into an email; choose your local councillor email adresses;  add your name and address; alter the contents as you see fit and send it off.  We have also created a template document for challenging Rushmoor’s plan.

Letter to Hart Councillors rejecting proposal to take 1,600 houses from Rushmoor
Rushmoor Local Plan Response Form

 

Please sign and share our petition and support our 5-point plan to change course:

 

Go to Petition

 

This story has been covered in Get Hampshire.

 

Link

Hart District is being asked to build too many houses

Housing Market Area Migration and housing capacity

Figure 1: Housing Market Area Migration and housing capacity

Hart District is being asked to build 7,534 houses in the planning period up to 2032 (now 9,134 as Hart is starting to plan for an additional 1,600 houses from Rushmoor).  This target is based on the Objectively Assessed Housing Need (OAHN) contained in the Strategic Housing Market Assessment (SHMA) carried out by Hart District and Rushmoor and Surrey Heath Boroughs. We believe this target is too high because the SHMA is based on a number of flawed assumptions:

  • Inward migration assumptions unrealistic
  • Average household size unreasonable
  • Jobs growth forecasts not credible
  • Overall adjustments lead to building rate higher than national requirement

These are set out in more detail below and in the submission to the Owens Farm (Hop Garden Road), Hook appeal. The overall impact of correcting these errors would be to reduce Hart District’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone and won’t need a new town at Winchfield or anywhere else.

Inward Migration Assumptions Unrealistic

Inward migration to this or any other district represents a “want” of people living elsewhere to live in Hart and not a “need”.  Many people may desire to live in Hart because it is one of the best places to live in the country, but no-one “needs” to move to live here in the strict sense of the word.  Indeed inward migration to Hart represents the unmet needs of other districts.  If Government policy is followed, then the housing, employment, education and other “needs” of the people “wanting” to move to Hart should be met by the local authorities where they currently live and thus the apparent need for housing in Hart arising from inward migration should substantially reduce.  There is no evidence presented in the SHMA to evaluate the impact of reduced inward migration to Hart from other districts as a result of those districts now being forced to meet their own needs, nor the impact of the implementation of the Northern Powerhouse.  Indeed London has now agreed to meet its own housing need in full, which should reduce the scale of inward migration to the HMA.

Notwithstanding the above, the SHMA makes a subjective judgement to cherry pick inward migration data from 2005-2010 as being the “most realistic” approach to take to future demographic modelling.  Moreover, it uses spurious statistical analysis to try to infer causation from a weak correlation (R2=~0.65) between housing completions and inward migration.  This is inherently flawed for a number of reasons outlined below.

First, of course it is self-evident that the period during which the HMA delivered most housing was when inward migration was highest.  However, as was argued above, this scale of inward migration represents unmet needs of other districts rather than the unmet needs of Hart.

Second, the period when we were building most and attracting most inward migration was during one of the longest uninterrupted periods of economic growth in history, supported by a large structural deficit in the national accounts and the biggest credit binge of all time.  Of course it ended in a spectacular bust and can in no way be described as a “normal” or “sustainable” set of economic conditions.  The economic conditions we are seeing now with more moderate growth linked to the need for the Government, companies and people to live within their means and reduce debt will be the situation for the foreseeable future and thus represent a more “normal” situation.

The period 2007-2012 includes the final year of the boom, the recession and the now more moderate pace of economic growth that surely more closely represents future conditions.  Indeed, as Figure 1 shows (data taken from Fig. 7.4 of the SHMA on p71) taking the period 2007-2012, the HMA delivered 2,942 new dwellings which at an average of 2.5 people per dwelling created capacity for an extra 7,355 people to live in the area.  Despite that, the HMA experienced an overall outward migration of 1,824 people.  It surely cannot be considered sound to base the future housing “need” on increasing inward migration projections when recent data shows that in fact the HMA is undergoing net outward migration despite creating significant capacity for more people to live here.

Accordingly, the additional 1,210 houses postulated in the SHMA arising from inward migration should be removed from the housing “need”.

Average Household Size Forecasts Unreasonable

Average Houshold Size projections for Housing Market Area

Figure 2: Average Household Size projections for Housing Market Area

 

Figure 7.7 of the SHMA (reproduced as Figure 2 above) shows that the trend in household size as measured by the census is slightly upward for the period from 2001 to 2011. This is in direct contradiction to both the 2008-based and 2011-based CLG projections.  Yet the forward projections used in the SHMA reverse the trend shown in actual data in the census and persist with the inaccurate forecasts of a continuing fall in the average household size.

Part of the justification for this is given as “at the time of the 2011 Census, the British economy was still in recession”.  This is factually incorrect as a cursory examination of the GDP numbers on the BBC website shows that the economy came out of recession in mid-2009.  It seems the forecasting “experts” are at a loss to properly explain this reversal of trend.

Moreover, given that the starting point for the SHMA projections is DCLG sourced figures, it would be somewhat odd for the DCLG forward projections not to include its own forecasts for household size.  There is therefore a significant risk that this part of the SHMA has double counted erroneous household size projections.

It is therefore inappropriate continue to assume a continuing downward trend in household size.  Surely a more prudent assumption would be to assume that the current household size is maintained and update that assumption and the SHMA as more real data comes to light.

Accordingly, the 1,500 additional houses in the SHMA related to the flawed household size assumption should be removed.

Jobs Growth Forecasts not Credible

The SHMA uses a set of jobs growth assumptions that are based on forecasts that are vastly in excess of what has been achieved in the most recent economic cycle.

The SHMA contains data on the historic rates of job growth for the HMA.  This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).

First, there is the period 1998-2008, covered by ABI data.  This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%.  Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum for the 3 years in question or a CAGR of 0.05%.

Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3: Discontinuity between ABI and BRES jobs data for Housing Market Area

Figure 3 shows a comparison of the BRES data and the ABI data that demonstrates the discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.

Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data.

Taking this 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum.

However, the SHMA uses as its central assumption that future jobs growth of 1,130 per annum will be achieved, equating to a CAGR of ~0.79%, nearly double what was achieved over the most recent economic cycle and far higher than that achieved during the unsustainable boom of 1998-2008.  Given the constraints on Government spending and tighter credit conditions that are likely to persist for some time due to tighter bank regulation, it is inconceivable that we will achieve an economic growth rate nearly twice that achieved during the last economic cycle. Figure 4 shows the comparison of these growth rates.

Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Figure 4: Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

Little justification for this is given other than it is based on Experian forecasts. The recent job creation history (2009-2012) showed jobs growth of 67 per annum as we came out of the recession.  67 jobs per annum equates to less than 6% of the jobs that the SHMA assumes we will create. Revised figures for 2013 demonstrate a CAGR of jobs growth from 2009-2013 at 0.52%, still well below the SHMA projections at a time the UK as a whole is creating more jobs than the rest of the EU put together.  This demonstrates that the Experian forecasts are pie in the sky and it beggars belief that such unproven Experian forecasts should take precedence over the actual real world achievement.

A further illustration of the outlandish nature of the Experian forecasts is given in para 7.70 of the SHMA.  In its forecast published in 2013, Experian assumes there were 145,000 jobs in the HMA in 2011.  Whereas the 2011 Census says there were only 122,300 and the BRES data says 125,000.  How can we trust Experian to forecast the future when it can’t even get the the past right?

Even the Employment Land Review produced by Rushmoor Borough Council described the Experian forecasts as:

“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”

The SHMA also says at para 7.85:

“…there are many ways labour markets can adjust to an increase in demand for labour that do not require an increase in the resident workforce. In summary these are:

  • A reduction in unemployment
  • A rise in economic activity rates
  • A shift away from part time working to full time working
  • An increase in double jobbing
  • A reduction in out-commuting
  • An increase in in-commuting

None of these changes require an increase in resident population, and all of them will be stimulated if
wage and salary levels increase.

In the modelling, allowance has been made for only one of these effects…”

No explanation is given for not taking into account the other ways in which the labour market can adjust.

In addition, if one compares the jobs forecasts to the population forecasts, the overall forecasts imply a massive, unrealistic increase in the percentage of people of working age in employment as can be seen in the table below:

 

Data Point2011 (Census)2011 (BRES)2031 (PROJ 2)2031 (PROJ 5)
SHMA Population (a) 272,394 272,394 307,578 322,278
People in employment (b) 122,300 125,000 162,233 170,223
Overall % in employment (b/a)44.9%45.9%52.7%52.8%
People over 70 (c) 28,559 28,559 51,164 51,164
People 5-19 (d) 67,375 67,375 73,206 73,206
People of working age (a-c-d)=e 176,460 176,460 183,208 197,908
% working age in employment (b/e)69.3%70.8%88.6%86.0%

This shows an increase from around 70% of working age people in employment to 86-88%.  No justification for this increase is given anywhere.

From the above, it is clear that the employment forecasts are outlandishly large and the SHMA does not even take into account most of the ways in which jobs can increase without leading to a need for more housing.  It is clear we should not be basing our housing requirement on such forecasts.

Figure 4.1 of the SHMA demonstrates that Hart in particular and the whole HMA enjoy high levels of employment and unemployment levels that are below the regional and national averages.

Therefore, the number of jobs to be created in the future should at least partially be a matter of “want” rather than “need”.  The future employment targets should be based on a realistic assessment of the capacity of the economy to create jobs in the private sector as it is these jobs that will support the largely state sector jobs in education and health that will be required to support the increased population.

As noted above para 7 of the NPPG states that local communities should be involved

“from the earliest stages of plan preparation, which includes the preparation of the evidence base in relation to development needs”.

Moreover, a recent legal opinion from Peter Village QC has said:

“There has been no regulation 18 consultation at all on issues such as employment, retail, transport, infrastructure (or, indeed, anything other than housing distribution). It is inconceivable that a coherent and sound local plan could emerge without addressing most (at least) of these issues.”

It therefore follows that the local community should be consulted upon the employment targets it wishes to set and the related scale of development required to meet that target.  No such consultation has taken place, nor is it planned which represents a significant flaw in the Local Plan process. The evidence from the petition indicates that local people are more likely to express a preference for a lower level of development.

Finally, despite enjoying high levels of employment, it is clear that we need to change the way we forecast jobs growth in the area as past methods have resulted in vast amounts of unused employment land and vacant retail outlets with examples illustrated here and here.

It is clear that past employment forecasts have been erroneous; that the future employment forecasts in the SHMA are spurious and do not represent a realistic assessment of future economic or employment growth rates; and the local communities have not been consulted upon this key issue.  Nevertheless, we can achieve enviable growth and employment rates in line with the requirement to “plan positively” without having to resort to such over-development.

Accordingly, the 5,100 additional houses in the SHMA related to the flawed employment forecasts should be removed.

Overall adjustments lead to building rate higher than national requirement

Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Figure 5: Hart Surrey Heath and Rushmoor SHMA adjustments applied at national level

Evidence presented at the examination of the Vale of the White Horse Local Plan has demonstrated that if the adjustments made to the baseline DCLG housing projections were applied on a national basis, they would increase the national output of housing to double the DCLG estimate of what is needed and triple the recent output of housing.

Applying a similar approach to the Hart, Rushmoor and Surrey Heath SHMA shows that on a national basis, we would be delivering 54% more housing than we need on a national basis, see Figure 5 above.  Surely it cannot be right that we are being asked to build at a rate that would lead to a surplus of housing.

England housing delivery actuals and projected 1946-2031

Figure 6: England housing delivery actuals and projected 1946-2031

The baseline DCLG projections for the combination of Hart, Surrey Heath and Rushmoor call for 790 houses per annum (SHMA Figure 7.3).  This equates to the DCLG projection of 220,000 houses per annum nationally (see figure 6 above).  This compares to recent performance of around 150,000 houses per annum.

The final SHMA, after taking into account past under-delivery, amount to a total of 24,413 houses (see table below), or an increase of 54.6% over the DCLG baseline figures.  The duty to cooperate might mean that Hart District has to build more houses than either Surrey Heath or Rushmoor as part of our Local Plan.

 Hart DistrictSurrey Heath BoroughRushmoor BoroughTotal Housing Market Area
Original SHMA7,5347,0579,82224,413
Proposed Transfers3,022(1,400)(1,622)0
New Total10,5565,6578,20024,413

If the same 54.6% uplift were applied to the DCLG projection, we would be building over 340,000 houses per annum nationally, more than double recent performance.

In recent years Hart has built more houses than it has been required to do and built at a rate above regional and national averages (SHMA Table 5.11).  It is beginning to look like the total of the local SHMAs are much larger than the overall requirement as defined by the DCLG. Surely it cannot be right that we are being asked to build at rate more than 50% higher than the DCLG suggests we need to meet overall demand.

Conclusions

The overall impact of removing these errors would be to reduce the overall housing target for the combined area by around 7,800 units.  This would reduce Hart’s overall housing target to around 6,100 units and crucially reduce Rushmoor and Surrey Heath’s target so they don’t need to ask Hart to build 3,100 houses for them.  This will mean that Hart will be able to satisfy the rest of its target from brownfield development alone.

The brownfield development tracker

Brownfield Development thermometer for Hart District

Given the recent success in quantifying the brownfield development potential in Hart District, we thought it would be good to set up a monitor to see how close we are to identifying all of the dwellings we need to meet the residual requirement of 4,000 units for the Hart Local Plan.

This of course assumes that we have to deliver the Objectively Assessed Housing Need (OAHN) in the Strategic Housing Market Assessment (SHMA).  There is a chance we might have to deliver an extra 3,100 houses for Surrey Heath and Rushmoor.  But equally there is also the potential for us to challenge the SHMA and end up with a lower housing target.

We will try and keep track of this as the process develops.

Rushmoor’s Employment Land Review has errors that reduce brownfield site availability

Vacant Block at Ancells Farm, Fleet, Hart District, Hampshire

Vacant Block at Ancells Farm, Fleet, Hart District, Hampshire

Rushmoor Borough Council has produced a draft Employment Land Review (ELR) on behalf of Hart District Council, Surrey Heath and Rushmoor.  We Heart Hart has examined this draft document and found some serious errors in the way they have calculated both the historic jobs growth numbers and the future jobs projections for the area. Moreover, after discounting the Experian methodology for calculating future jobs growth saying:

“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”,

they recommend that the scenario that is used for testing should be based on the numbers for housing development contained in the SHMA, which themselves are inflated by the self same Experian forecasts they earlier dismissed as unreliable. This is clearly an absurd position that results in the forward B-class job projections (598 per annum) being nearly double the rate (300 per annum) that would be achieved if we continued at the rate of growth that was delivered between 1998 and 2012.  The impact of this is that the amount of employment land we need is being over-stated and so reducing the amount of brownfield land that might be available for housing.  This represents a great opportunity for Hart Council to challenge Rushmoor to re-visit the ELR and revise it so that more brownfield land comes available across the three districts.

We have asked several questions about the errors we found, but have not received satisfactory responses. We urge you to contact your councillors and ask them to challenge Rushmoor to come up with more realistic estimates and revise the ELR before it becomes final and sign our petition:

 

Go to Petition

 

The detail of the analysis is shown below.

ELR Table 8.2

ELR Table 8.2

The starting point for the analysis is Table 8.2 that shows the forecast employment change in a number of different types of jobs, from which it is possible to derive the ratio of B-Class jobs to all jobs at 53% (17,428/32,906). B-Class jobs means those jobs that require office space or light industrial units, rather than an indication that they are somehow inferior.  Then we must look at Figure 7.12 that allegedly compares the historic rate of growth of B-Class jobs to the forward projections.

Figure 7.12 ELR

Figure 7.12 ELR

By inspection, Figure 7.12 shows the trend in B-Class jobs as approx 555 per annum from 2002-2012.  The data from Table 8.2 allows us to derive total job growth of around 1,048 per annum.  However, as we shall show below, this number is far in excess of the actual job growth achieved according to the SHMA.

The SHMA contains data on the historic rates of job growth.  This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).

First, there is the period 1998-2008, covered by ABI data.  This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%.  This would equate to a growth rate of B-Class jobs of 382 per annum, far lower than the 555 jobs per annum shown in figure 7.12.

Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum (35 B-Class per annum) for the 3 years in question or a CAGR of 0.05%, again far lower than the 555 in figure 7.12.  It is difficult to see how the 555 number was derived since it is much higher than either period covered in the SHMA.  Despite repeated questions, no one has been able to explain how they derived their number for Figure 7.12.

Comparison of the BRES data and the ABI data shows a discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.

Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data.  This would equate to B-Class jobs growth rate of 280 per annum, or about half the number in Figure 7.12 of the ELR.

Taking the 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum, or 300 B-Class jobs per annum.

However, the scenario recommended for testing in the ELR assumes a rate of B-Class jobs growth of 598 per annum (or total jobs growth of 1,128 per annum), nearly double the rate that would represent a forward projection of past performance over the economic cycle.  Incidentally, this is almost the same number as the future jobs growth number contained in the SHMA, which is based on the same Experian forecasts that the ELR itself discredits.

 

Top QC says Hart Council’s position on the Local Plan is “hopeless”

Scales of Justice weigh against Hart District Council

Scales of Justice weigh against Hart District Council

 

Top planning QC, Peter Village has produced a devastating legal opinion on Hart District Council’s Local Plan process and pronounced that they are in a “hopeless position“.  Hart Council have received this opinion, but have refused a meeting to discuss ways of improving the plan.  In fact, at last night’s council meeting, council leader Stephen Parker dismissed the report as “just one opinion among many”.

It is imperative that Hart gets a high quality local plan in place quickly and fends off the demands from Surrey Heath and Rushmoor Borough Councils to build an extra 3,100 houses in Hart.  The council’s attitude displays a staggering level of arrogance and complacency that can only lead to more delays and extra costs to get the plan right.  We urge all voters to press their council candidates to push to get the Local Plan process back on track by adopting our 5-point plan and dropping all ideas of a new town in Hart District.

The essence of the opinion is:

  • The Regulation 18 public consultation in the autumn of 2014 addressed housing options and did not consider other vital issues such as employment, retail, transport and infrastructure.
  • Hart District Council said in April 2014 that they would conduct a second Reg 18 consultation in March 2015, which they have since dropped and now intend to proceed directly to a Regulation 19 consultation on the Draft Plan for Final Inspection.  This plan is likely to fail because either the Local Plan will not contain all the elements it should, or they will not have consulted on all of the things they should consult upon.
  • Hart have not consulted upon the demands from Surrey Heath and Rushmoor that Hart build 3,100 houses for them.
  • Hart have not considered a medium growth “policy on” scenario of not meeting the full housing need on environmental grounds.
  • Hart have not properly considered the brownfield capacity of the district, highlighting that the capacity could be up to 3,500 dwellings, far more than the 750 dwellings Hart is still insisting upon.

Reader may recall that set out a 5-point plan to address these issues and this is summarised below:

  • Create a medium growth scenario with a lower housing requirement than the current high growth scenario to give an option to reduce the environmental impact of development.
  • Create a formal brownfield option and invite a competition to design the best way of using our brownfield land.
  • Do the work and consult upon the additional elements of a proper Local Plan such as employment, education, transport, retail and other infrastructure.
  • Consider the Environment and Landscape by carrying out proper habitat studies and landscape character assessments.
  • Fix the management and governance problems within Hart Council that have resulted in the past failure and current hopeless position.

If you want to press for change, please sign our petition:

 

Go to Petition

 

The full Legal Opinion and our latest Press Release can be found below:

Peter Village QC Legal Opinion
We Heart Hart Press Release 1 May 2015

This has been covered in the Basingstoke Gazette.

 

QC Opinion

Press Release

 

How to make a better Local Plan for Hart District

Protect our green fields

Protect our green fields

We know that progress on the Local Plan for Hart District is slow and that it is not going in the direction many would like to see.  We thought it was time to outline an alternative approach, and see if Hart Council and the candidates for election will change their minds. Below we set out a five point plan for change:

  • Create a medium growth scenario
  • Create a formal brownfield option and invite a competition to design the art of the possible
  • Do the work and consult upon the additional elements of a proper Local Plan
  • Consider the Environment and Landscape
  • Fix the management and governance problems

1.  Create a Medium Growth Scenario

We need to work on creating a reasonable, alternative “medium growth” scenario to go alongside the current “high growth” scenario. We have posted earlier about why we believe the SHMA is flawed (as shown here and here) and is forcing us to build too much –  7,534 houses in Hart plus 3,100 extra from Surrey Heath and Rushmoor.  Hart District Council should work with Rushmoor and Surrey Heath work to create a joint new, “policy on” lower housing requirement for the whole Housing Market Area that:

  • Takes account of the environmental damage that large scale over-development would cause to our valuable countryside and the green belt in Surrey Heath
  • Uses more realistic jobs growth assumptions of say around 650-750 jobs per annum over the cycle which is above what was achieved over the last economic cycle as opposed to the existing assumption in the SHMA of 1,130 jobs per annum
  • Uses more realistic inward migration and household size assumptions.

The more realistic assumptions above could reduce the overall housing “need” for the combination of Hart, Rushmoor and Surrey Heath by around 8,000 dwellings from 23,600 to 15,790. We believe this would relieve the pressure on all three districts, and in particular, reduce the pressure on Hart to take the unmet needs of Surrey Heath and Rushmoor Boroughs.

2. Create a formal brownfield option and invite a competition to design the art of the possible

We have already demonstrated that Hart has no effective brownfield strategy.  Hart Council should create a new, formal “reasonable suitable alternative” option of meeting the housing need solely through brownfield development. This should involve the following:

  • Creating a complete database of all of the potential brownfield sites in the district, including those not yet in the SHLAA and those not yet formally promoted to the council, including sites such as Bramshill House, Pyestock (aka Hartland Park), Sun Park, Ancells Farm, Bartley Wood, Fleet High St and all of the run down town centres (e.g. Fleet, Yateley, Blackwater and Hook).
  • Inviting leading architects to compete to produce some visionary outline schemes of what a “brownfield solution” might look like for the district, taking into account changing demographics, changing shopping habits driven by the internet and achievable housing densities.
  • Organising a conference with the architects, land owners, developers and local community representatives with the objective of identifying the art of the possible for brownfield development amongst the competing solutions from the architects.

This could be done in conjunction with the neighbouring authorities of Surrey Heath and Rushmoor.

3. Do the work and consult upon the additional elements of a proper Local Plan

Hart District Council needs to work on the other elements that should make up a local plan such as education, retail, transport, employment, meeting the needs of the ageing population and other infrastructure.  Hart should conduct suitable, high level strategic analysis to build an evidence base to answer the following questions:

  • Education. How many school places will we need and where in both the current “high growth” and proposed “medium growth” alternative requirement scenarios? How might these be delivered and what are the costs of the alternatives?
  • Retail. What is the range, type and location of shops required across the district, taking into account changing shopping habits, the growth of the internet, changing demographics and the alternative growth scenarios?  How will we regenerate our high streets?
  • Transport. What investment will be required in the major road and rail infrastructure under both growth scenarios? Considering alternative sites for each of the development options (including the new “brownfield option”), what investment will be required in minor roads, making broad assumptions on the location of alternative sites?
  • Employment. This review should be conducted across the Hart, Surrey Heath and Rushmoor.  What types and quantities of employment land will be required under the alternative growth scenarios, taking into account changing work structures and habits; what is the current forecast surplus/deficit in 2032? Would any extra employment land need to be found?  How much current employment land could be released for housing?
  • Other infrastructure. It is likely that a new town, particularly in Winchfield, would require even further infrastructure spending due to its current lack facilities such as mains sewage and mains gas. What is the cost of providing additional infrastructure for a new town such as sewage, gas, roads, electricity, rail etc?
  • Ageing Population.  What type of housing is required to meet the needs of the 6,850 extra people aged over 75 and the extra 3,620 people who will be suffering from dementia or have some sort of mobility problem and where should it be located?

For each option and scenario Hart should outline the total cost of infrastructure spending required and the likely contribution from developers so that a proper financial model can be created.

4.  Consider the Environment and Landscape

Fourth, Hart should conduct the other studies that are required to update the evidence base such as the landscape character assessment and an assessment of the potential damage caused to our wildlife by over-development.

 

Once this work has been completed, Hart District Council should carry out a new Regulation 18 consultation on the above that includes both a medium and high growth scenario and the properly evaluated options for meeting the housing need including the new proposed “brownfield” option. It would be preferable if the current “Option 4 – New town at Winchfield” (or indeed a new settlement anywhere in Hart) was dropped as an option. It will be important for the council to step up its engagement efforts during this period to ensure that a much larger proportion of the public responds to the consultation.

After the results of the consultation is known, firm up a preferred growth scenario and delivery option(s) to work up into a more detailed Local Plan and conduct an exercise to ensure democratic endorsement of the preferred option. This could take the form of a district wide referendum or a series of Parish Polls, followed by a Regulation 19 consultation before submission to the inspector.

 

5.  Fix the management and governance problems

Finally, Hart need to work on the setting up the Local Plan project properly and address the governance deficiencies. There is clearly no properly defined scope or deliverables as the recent questions to the Planning Inspector demonstrate.  Moreover, the timeline keeps slipping as we were originally supposed to have been consulted on a draft plan in March 2015, and it is clear that Hart is nowhere near that milestone even though it has dropped that consultation from its plan.  This indicates the Local Plan project is not properly resourced. The Council needs to appoint a suitably qualified, experienced project manager, follow a properly recognised project management methodology such as Prince 2 and invest in the proper resources required to carry out the project on time to proper quality standards.

Given the prior failure of the earlier Local Plan at inspection and the current hopeless path the new Plan is taking, it is also clear that the governance of the Local Plan is deficient, with power effectively concentrated into the hands of only two people. The Council needs to explore ways of separating powers so that there is better transparency and accountability on both the “officer” and “member” sides. We suggest that the project should report to the joint chief executive who is not also in charge of planning; that roles of council leader and portfolio head for planning are carried out by two separate people and the council members elect a more proactive and capable chairman. This should lead to a wider range of opinions to be heard and appropriate checks and balances to be implemented.

It remains to be seen if our Parliamentary candidates or our Hart District Council candidates will endorse this plan.

If you would like to join the campaign to change Hart’s mind, please sign and share our petition.

 

Go to Petition

 

 

We Heart Hart Presentation to Crondall Parish Council

We Heart Hart were delighted to be invited to speak at tonight’s parish council meeting at Crondall.

 

The presentation went well with lots of interest in the Hart Local Plan and how we might persuade Hart Council to think again, particularly to focus on brownfield development and fight off the demand for us to build 3,100 extra houses for Surrey Heath and Rushmoor Borough Councils.  Lots of interest in our leaflet too.

 

A copy of the presentation and leaflet are available for download below.

 

We Heart Hart Presentation to Crondall Parish Council

 

We Heart Hart Campaign Flyer

 

Presentation