Lock, stock and two smoking barrels

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

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

Dear Messrs Daryl Phillips and Stephen Parker,

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

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

There are a number of components to this:

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

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

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

 

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

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

  1. Deliverable and developable sites not included

[updated with this note]

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

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

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

  1. Sites missing from NHB but in the SHLAA

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

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

 

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

 

  1. Discrepancies between capacity in NHB and SHLAA

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

 

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

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

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

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

  1. Range of meanings of “not currently developable”

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

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

  1. Lack of discussion about economics

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

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

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

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

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

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

Yours sincerely,

 

cc:           Peter Kern, Chairman of Hart DC Standards Committee

Ranil Jayawardena, MP

 

Appendix 1:

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

See more at our consultation page:

link

Winchfield Action Group and We Heart Hart submit objections to Hart’s consultation process

Designated area of outstanding natural profitability

Designated area of outstanding natural profitability

As you may know, Hart Council is about to embark upon a new consultation about our housing options as part of the Local Plan process.  We Heart Heart and Winchfield Action Group (WAG) have significant concerns about the way this consultation has been constructed and submitted a number of detailed points to the council.  In addition, WAG will be making a statement at the Cabinet meeting tomorrow. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

The main thrust of the objections is as follows:

  • Overall the consultation is too complicated and the instructions are not clear.  Given that a large number of submissions to the last consultation were invalid, this is a serious concern that needs to be addressed.
  • The Council have not explained why they have reduced the brownfield capacity of the district to 400 units when they said there was 1,800 as recently as October. The consultation also makes no reference to the fact that the Council is currently seeking more brownfield sites across the district.
  • The consultation unfairly biases its whole analysis towards the conclusion that we must build a new town in Winchfield.

There are also a number of other points made in the detail.

The statement and the detailed point can be found on the downloads below.

Statement to Hart Cabinet
Statement to Hart Cabinet
 
Detailed feedback on Housing Options Consultation
Detailed feedback on Housing Options Consultation

Is housing capacity in Fleet really only 30 dwellings?

Housing Capacity of 30 units in Fleet Hampshire

Housing Capacity of 30 units in Fleet Hampshire

Hart Council has published a booklet as part of its forthcoming consultation setting out its estimate of housing capacity for each parish in the district.  There are a number of strange anomalies in that booklet, including stating the capacity of Bramshill to be zero, when there is the old Police College ripe for redevelopment and Elvetham Heath, again set to zero when Hart even identify a capacity of 45 homes in their main consultation document.

But the most egregious anomaly is the estimate of only 30 units in Fleet itself.  This misses out many brownfield sites that are ripe for redevelopment such as:

  1. The complex of offices that includes Admiral House, Flagship House, Hart Council Offices and the Harlington Centre that were identified and promoted by Fleet Future:
Vacant Office Admiral House, Harlington Way, Fleet, Hart District, Hampshire

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

Harlington Centre, Fleet, Hart District, Hampshire

Harlington Centre, Fleet, Hart District, Hampshire

Vacant Office Flagship House, Fleet, Hart District, Hampshire

Vacant Office Flagship House, Fleet, Hart District, Hampshire

Hart District Council Offices

Hart District Council Offices

2. The derelict offices on Fleet Road, again identified by Fleet Future:

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

3. Fleet Police Station:

Old Police Station in Fleet, Hart District, Hampshire

Old Police Station in Fleet, Hampshire

4. The still vacant units on Ancells Farm that have not yet been taken up by Stonegate:

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

Vacant Office at Ancells Farm, Fleet, Hampshire

5. The 119-acre Pyestock (aka Hartland Park), which has capacity for thousands of homes and where development of a new warehouse has stalled:

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

 

It is ridiculous, and some might say negligent, that Hart Council should be promoting a new town at Winchfield and/or urban extensions in Fleet or Hook for the Local Plan when there is plenty of vacant and derelict land that could form a more sustainable solution. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

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

Time to celebrate we don't need so many houses

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

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

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

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

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

Critique of Hart SHMA
Critique of Hart SHMA

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

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

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

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

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

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

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

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

Hart Council missing out key information about housing options

Hart District Council Offices

Hart District Council issuing misleading information about housing options

Hart Council has just published its new Housing Options paper in relation to the Local Plan, in preparation for running a consultation from November 23 2015 to January 15 2016. We believe the information contained in that paper is misleading for a number of reasons and have some suggestions on how you might respond to the consultation.  In summary the issues are:

  1. The SHMA is currently being revised and likely to reduce the housing need, so why are we being consulted on a housing requirement that is no longer valid?
  2. The SHMA has been challenged by an independent expert who says we don’t need so many houses.
  3. Hart’s estimate of brownfield capacity is way too low, and far lower than they said as recently as October 1 2015.
  4. Government rules have been changed to encourage more brownfield development and this paper makes no mention of this.
  5. The infrastructure costs of a new town are enormous, but the paper doesn’t clearly set out the economic consequences of the choices we make on housing options.

Housing allocation out of date

The housing need assessment is based on the current version of the Strategic Housing Market Assessment (SHMA), and they do not mention in the paper that the SHMA is currently being revised to take account of new Government population and household projections.  These new projections show a big reduction in forecast population from 322K used in the SHMA to 289K for the whole housing market area and a reduction of 1,602 in Hart household projections.  It seems reasonable to assume that Hart’s housing allocation will therefore fall, but this is not mentioned at all in the consultation paper.

SHMA is invalid

The Housing Options paper does not take account of the opinion of independent expert, Alan Wenban-Smith that the SHMA says we are being asked to build too many houses.  This means that the paper is asking us to consider how we might build houses that aren’t needed and is therefore invalid.

Estimate of brownfield capacity is too low

Back in November 2014, Hart Council said we had capacity for 750 dwellings on brownfield sites. Very few or none of those sites have been granted permission since then. At cabinet on October 1 2015, the joint-CEO of Hart Council said that he thought the brownfield capacity had increased to around 1,800 units. We said at the time we thought this was a low estimate and it could be in the range of 2,400-3,688. However, the new paper says that brownfield capacity is now only 400 units.  The paper pours cold water on the notion that the former police college at Bramshill can be re-developed, but who in their right mind would want to see a Grade 1 listed building start to decay, and who would want to preserve the hideous 1970’s accommodation blocks?  This is clearly a site ripe for redevelopment, and the environmental impacts should be low compared to the prior use of the site.  So, the question remains, what has happened to the other 1,400+ units and why aren’t Hart taking account of them?

Government has made brownfield development more attractive

The Government has also just relaxed the rules about building on brownfield sites to make it more attractive.  This makes it more likely that the brownfield capacity identified in the Stonegate report can be delivered.  The Hart paper fails to mention this. The paper also fails to mention that Hart has kicked off a process to identify even more brownfield sites across the district, but the results of that study won’t be known for some time.  It does seem odd to be so definitive about the so-called lack of brownfield capacity when there are so many positive developments underway.

Astronomical Infrastructure Costs

Hart have published some analysis to show the infrastructure requirements of a new settlement.  They haven’t been definitive about how much this would cost, but it would include a new motorway junction, significant changes to existing roads and bridges, a new sewage works, 4 new schools and a new railway station.  Our estimate of the cost of this infrastructure is £300m+.  A realistic expectation of the developer contribution for 4,000-5,000 houses would be £40-50m.  Hart already have an infrastructure funding deficit of £78m.  It is clear that we cannot afford the infrastructure costs of a new town, and that existing settlements would be starved of investment if it went ahead. The new housing options paper makes very little reference to the economics of development for any of the approaches it identifies.  Surely, we should know about the economic consequences of the housing options choices we make?

It is becoming increasingly clear that the housing options paper and the associated consultation is a pig-in-a-poke, but nevertheless as it is there we must respond to it.  It looks increasingly like a faction of the council is hellbent on concreting over large swathes of our countryside, despite all the evidence that we don’t need to.

We urge you to Vote against Approach 3 (a new settlement at Winchfield).  But when asked for any other comments, use this article to ask them to think again about brownfield. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

Community Campaign Hart Council Chairman to discuss brownfield development with Ranil

Hart District Council Offices

Hart District Council Offices

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Government to extend “planning in principle” rights to green fields

Example of Urban Sprawl

Example of Urban Sprawl

The Government appears to be trying to extend the recently announced “planning in principle” rights to green field developments. This could mean tens of thousands of new homes in green field areas will be forced upon communities that do not want them.

We have previously applauded the Government for introducing this right to brownfield sites. Just three weeks ago David Cameron, the Prime Minister, said that the new “planning in principle” changes would apply to brownfield sites like former car parks and industrial areas. However Government documents said the new power will apply to “housing identified in local plans and neighbourhood plans” which include greenfield areas.

One document states: “The Government proposes to legislate to enable the Secretary of State to grant ‘permission in principle’ via a development order to land that is allocated for development in locally produced plans and registers.”

This development may have important implications for the Hart District parishes (e.g. Winchfield, Odiham, Fleet) that are in the process of creating their Neighbourhood Plans and of course for the Hart Local Plan.  Surely, this will mean that will be more reluctant to identify potential sites for development because Hart Council Planners will no longer have the powers to block inappropriate schemes nor to insist that the design, density, size and location of homes is in keeping with local areas.

This proposal significantly undermines local democracy and should be opposed.

 

Community Campaign in bitter clash with We Heart Hart

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

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

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

Hart District Council takes aim at the Heart of Hart

Community Campaign takes aim at the Heart of Hart

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

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

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

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

Community Campaign Hart takes aim at the Heart of Hart

Hart District Council takes aim at the Heart of Hart

Community Campaign Hart takes aim at the Heart of Hart

Community Campaign Hart (CCH) have published a new newsletter on their website that calls for a new settlement to destroy the Heart of Hart in Winchfield.

In their article they make criticism of We Heart Hart and the good residents of Winchfield, and come to the conclusion that the only viable option for delivering the housing we need is a new settlement of 3,000-5,000 houses in Winchfield.  In their article they make a number of assertions that we believe are false, and will now seek to correct them, point by point.  But first, it is important that we start with the areas where we agree with CCH.

Points of Agreement

CCH say:

Until Hart have an LDP which meets the approval of a Government-appointed inspector, developers are in effect able to build on almost any greenfield site they choose

We broadly agree with this, although as in the case of Hop Garden Road in Hook, sometimes common sense can prevail especially now that Hart has more than 5 years of land supply.  However, if CCH are so concerned about the lack of a Local Plan, they should work more closely with We Heart Hart and others to ensure that Hart Council takes proper steps to improve the management of the Local Plan project that has slipped its timescale by two years within two years.  They would do better to use their time at council meetings to ask questions about the local plan rather than seek to stifle difficult questions.

Points of Difference

1. CCH say:

There just isn’t enough brownfield land available to accommodate that number of new homes, unless we are going to build high-rise tenement blocks along the length of Fleet Road.

This is simply not true on a number of levels.  First, the council hasn’t even created a proper register of brownfield sites so it hasn’t properly assessed capacity.  Second, our own work has shown there’s capacity for between 2,438 and 3,688 units, compared to the remaining unsatisfied “need” of 2,900 given at the last cabinet.

Derelict Offices in Fleet, Hampshire

Derelict Offices on Fleet Road in Fleet, Hampshire

Third, parts of Fleet Road are a disgrace to the district and should be redeveloped, not with tenements, but with mid-rise (say 3-4 storey) high quality apartments to help young people get on the housing ladder.  Finally, there is brownfield capacity all over the district including Ancell’s Farm, Bartley Wood, Pyestock, Bramshill and Guillemont Park.  They really should get out more and see all of the vacant offices around the district.

2. CCH say:

With a mainline railway station far closer to it than to any other new development in Fleet; with the option to integrate new roads onto the A30 and through to the M3; together with sufficient scale to fund three new primary schools and a new secondary school, Winchfield strikes many as being the best compromise

This is economic incompetence of the highest order.  The council’s own assessment of infrastructure needs points to costs of over £300m for a new town including the schools, but not including improvements to healthcare.  The ballpark estimate for developer contributions made by a senior Hart Councillor is around £40m.  There’s already a £78m infrastructure funding deficit in the district and £1.9bn across Hampshire.  Not only would a new town at Winchfield destroy green fields, it would destroy ancient hedgerows and put at risk SSSI’s and SINCs, but it would no doubt further increase congestion in Fleet and Church Crookham.

3, CCH say:

Consequently they have resorted to social media and other marketing techniques to promote the ‘wehearthart’ message.

However, their messaging is incomplete. They point to the council wishing to build a new town at Winchfield and seek to demonize anyone who may have reached the conclusion, however reluctantly, that a new town at Winchfield is the least worst solution out of an abhorrent set of options. They do not explain what the alternatives are, as the National Planning Policy Framework (NPPF) mandates that this level of housing must go somewhere within Hart’s borders

We do not see what is wrong with communicating with the public using social media on the serious issue of the Local Plan, particularly when the council gets its own facts wrong.  However, We Heart Hart has explained what the alternatives are at some length, and the CCH Chairman of the council sought to have questions that we raised to indicate a different path censored at council meetings.  The alternatives are:

a) Reduce the alleged housing need by challenging the SHMA, particularly taking into account the latest DCLG population forecasts that indicate a lower population in 2031 than assumed in the SHMA and the reducing ridiculous jobs forecasts.  CCH would do well to engage with this debate instead of seeking to censor it.

b) Explore the options for reducing the assessed housing need by exploring so called “policy on” options to protect the environment and ecology.  Note that Winchfield is beautiful countryside in its own right, but is also within the 5km zone of influence of the Thames Valley Heath SPA.

c) Properly get to grips with brownfield options by establishing a brownfield register, actively encouraging landlords to redevelop their derelict sites and exploring the use of Compulsory Purchase Orders on sites that have sat vacant for years with no apparent signs of progress (e.g. Hartland Park aka Pyestock).

Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

Brownfield site: Hartland Park (Pyestock) near Fleet, Hart District, Hampshire, warehouse development not started

CCH need to wake up, smell the coffee, listen to Ranil Jaywardena and use their talents to establish a different vision to protect the countryside they profess to love rather than coming out with incomplete, inaccurate nonsense.  Be careful who you vote for in next year’s local elections.

This story now covered in the local press, see here.

Questions for Hart Council meeting on 29 October 2015

Hart District Council Offices

Hart District Council Offices in Fleet, Hampshire

Hart District Council meets again on 29 October at 7pm.  We have been busy preparing some questions for them on brownfield capacity; the impact of the new Government announcements about brownfield sites; Ranil’s statement about protecting our green fields; when they might use Compulsory Purchase Orders to acquire vacant sites; the inaccurate assumptions in the SHMA and the slippage in the timetable for the Hart Local Plan.

The questions can be downloaded from the button, and are re-produced below:

Questions to Hart Council on 29 October 2015
Questions to Hart Council on 29 October 2015

To Daryl Phillips

  1. Please provide an analysis, including SHLAA ref, site name and description, site area in hectares, and expected yield, of the sites that have been used to build up the estimate provided at cabinet on 1 October 2015, when you asserted that the ‘guesstimated’ capacity for brownfield development in the district up to 2031 was now 1,800 dwellings (up from the 750 dwelling estimate of a year ago and compared to the 2,438 units estimated by WeHeartHart).
  1. How will the recent Government announcement extending permitted development rights indefinitely and allowing automatic planning permission in principle on brownfield sites impact your assessment of brownfield capacity?

To Stephen Parker

  1. Do you agree with our local MP who says: “I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in NE Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield…I’m against these developments – indeed, this sort of large-scale top-down volume-led development generally – as I do not believe they are necessary to deliver the housing we need in our area. Looking at Hart District specifically for a moment, as the largest part of the constituency, I believe that the local housing demand can be met on brownfield sites”?
  1. What criteria would you use and how long would a brownfield site need to be vacant, with no sign of redevelopment before the council would consider using Compulsory Purchase Orders (CPOs) to ensure that we can build modern apartments for young professionals who can’t otherwise buy a home in our area?
  1. How many sites would meet those criteria and how many dwellings might they yield?
  1. Given that the baseline estimate of the number of households in Hart in 2011 and 2031 used in the SHMA was 35,760 and 42,220 respectively, but the new DCLG 2012-based household projections (Table 406) for 2031 show that Hart will have only 40,618 households, a reduction of 1,602, can you confirm that these revised figures will lead to a corresponding reduction in Hart’s assessed housing need?
  1. When will the 6,560 excess housing requirement for the whole HMA be removed from the assessed need in the SHMA given that the new DCLG 2012-based population projections (Table 426) show a population projection of only 289K for the HMA for 2031, compared to the SHMA (Appendix F, Figure 2)
Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

Hart Rushmoor and Surrey Heath SHMA Appendix F Figure 2

starting assumption of 307K and the final population estimate of 322K used to determine housing need?

  1. What justification is there for assuming the significant social changes implied in the SHMA given that the SHMA increases the number of houses that need to be built based in part on very ambitious jobs forecasts which when combined with the population projections in the SHMA results in a massive increase in the proportion of people of working age who will be in employment (see 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%

 

  1. What steps will be taken to adjust the jobs forecasts in the SHMA given that, a) the revised BRES job numbers for 2013 show that the compound annual growth rate in jobs we have achieved since the recession ended in 2009 is ~0.5% which is much lower than the ~0.8% growth rate assumed in the SHMA for the period 2011-2031, b) this comes at a time when the UK is creating more jobs than the rest of the EU put together and c) it is inevitable we will experience at least one more recession during the plan period?
Hart Surrey Heath and Rushmoor Jobs Growth rates 1998 to 2013 compared to SHMA

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

  1. What steps are being taken to accelerate the delivery of the Local Plan given that the recent Government announcement indicated that Local Plans need to be brought into force by 2017 and the current LDS shows the Local Plan being adopted in Summer 2017 and other DPD’s in Autumn 2018 and the track record of past slippage?