Questions for Hart Council meeting on 29 October 2015

Posted on October 17, 2015October 17, 2015

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

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To Daryl Phillips

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).

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

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”?

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?

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

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?

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

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

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 Point	2011 (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%

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

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?

Housing allocation for Hart, Rushmoor and Surrey Heath should reduce by 6,560 according to new DCLG figures

Posted on October 15, 2015October 16, 2015

Department for Communities and Local Government (DCLG)

The housing allocation for the combined Housing Market Area (HMA) of Hart, Rushmoor and Surrey Heath should be reduced by by 27.7% or 6,560 houses, taking away the risk that Rushmoor and Surrey Heath will ask Hart to build 3,000 houses for them and ensuring Hart’s own requirement can be built on brownfield sites only according to new population projections that have been released by the DCLG.

Figure 1: Hart Rushmoor and Surrey Heath SHMA Appendix F

The SHMA worked by taking as a starting point earlier Government figures that showed the combined population of the HMA would be 307K (PROJ 2 circled in Figure 1 above) and this was inflated by increasing the assumptions on inward migration, average household size and jobs growth to arrive at a final figure of 322K (PROJ 5 circled in Figure 1 above).

Hart Rushmoor and Surrey Heath SHMA Appendix G Figure 1

Figure 2: Hart Rushmoor and Surrey Heath SHMA Appendix G

Interestingly, revised population forecasts were published by the Government as the SHMA was being finalised that showed that the start point population forecast should be reduced to 295K (circled in Figure 2 above), but amazingly these changes were not used to reduce the assessed housing need. If they had been used, the total amount of housing that would be required for the HMA would have reduced by 208 per annum (see Figure 3 below), or a total of 4,160 dwellings out of a total objectively assessed housing need (OAHN) of 23,600.

Hart Rushmoor and Surrey Heath SHMA Appendix G Figure 2

Figure 3: Hart Rushmoor and Surrey Heath SHMA Appendix G

Now the latest DCLG figures (Table 426) have reduced the population forecast for 2031 for the whole HMA down to only 289K, a reduction of 6,000 people, which equates to a reduction of a further ~2,400 houses (@2.5 people per property).

Taken together these reductions in population forecasts would reduce the whole housing need for the HMA by 6,560 houses of the 23,600 or a reduction of a stunning 27.7%.

We wonder when Hart Council, Rushmoor and Surrey Heath councils will take these new figures into account in the Local Plan.

Government makes brownfield development easier but steps up pressure on Local Plans

Posted on October 12, 2015October 12, 2015

Number 10 Downing Street

The Prime Minister has made an important announcement today about brownfield development and added to the pressure on Councils to produce Local Plans by 2017.

First, on brownfield development, the Government has made two announcements:

Automatic planning permission in principle on brownfield sites – to build as many homes as possible while protecting the green belt

the PM also announced that a temporary rule introduced in May 2013 allowing people to convert disused offices into homes without applying for planning permission will be made a permanent change – after almost 4,000 conversions were given the go ahead between April 2014 to June this year

These are important developments as they make it easier to make use of the massive surplus of brownfield land in the district so we can maximise brownfield capacity and have no need to build a new town at Winchfield or anywhere else.

Second, the Government has increased the pressure on councils to get Local Plans in place by 2017, saying:

Councils have a key role to play in this by drawing up their own local plans for new homes by 2017. But if they fail to act, we’ll work with local people to produce a plan for them….Following today’s announcement, if councils fail to produce and bring into force an up to date plan for new homes by 2017, we will work with local people to ensure one is drawn up. Ministers will shortly be bringing forward further details of how best to intervene when councils have failed to get started on their plans

This potentially puts Hart District Council (and potentially other Hampshire districts) on a collision course with Government, because it has repeatedly failed to hit its own deadlines for the Local Plan and its latest Development Schedule shows the main Local Plan not being adopted until Summer 2017, with other development plan documents not due to be adopted until Autumn 2018.

We wonder when Government Inspectors will be knocking on the door of local people asking what they want from a Local Plan?

Hart household projections fall according to new figures from DCLG

Posted on October 10, 2015October 10, 2015

Cows in Winchfield, Hart District, Hampshire

Do we want to lose our cows to concrete?

In a piece of good news, revised population projections published by the Department of Communities and Local Government (DCLG) show that Hart will have fewer households in 2031 than were assumed in the Strategic Housing Market Assessment (SHMA). This should have the effect of reducing the housing requirement being imposed on Hart District as part of the Local Plan. This might reduce the remaining 2,900 houses left to grant permission for and make it more likely we can meet all of the remaining need from brownfield sites.

Local Authority	2011 households	SHMA start point for 2031 using 2011-based population projection	New projection for 2031 using 2012-based population projection	Change between 2011-based and 2012-based projections	SHMA end-point for 2031
Hart	35757	42220	40618	-1602	43291
Rushmoor	36559	40830	42362	1532	46381
Surrey Heath	33632	38170	38321	151	40689
Total	105948	121220	121301	81	130361

However in other news, the same new figures for Rushmoor and Surrey Heath show higher projections for households up to 2031 than were assumed in the SHMA. This might increase the housing requirement for Surrey Heath and Rushmoor and they may ask that Hart builds those houses for them.

What is clear is that the SHMA then makes several dubious adjustments to the baseline DCLG projections that add a further 9,000 or so houses to the total for the housing market area that need to be challenged.

The DCLG figures can be found here and here. The SHMA can be found here.

If SHMA adjustments were applied nationally we would be building too many houses

Posted on October 10, 2015October 10, 2015

Figure 1: 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 1 above. Surely it cannot be right that we are being asked to build at a rate that would lead to a surplus of housing.

Figure 2: 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 2 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 District	Surrey Heath Borough	Rushmoor Borough	Total Housing Market Area
Original SHMA	7,534	7,057	9,822	24,413
Proposed Transfers	3,022	(1,400)	(1,622)	0
New Total	10,556	5,657	8,200	24,413

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.

Latest jobs growth figures well short of SHMA estimates

Posted on October 8, 2015October 8, 2015

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

The Government have released the revised BRES job numbers for 2013 and these show that the jobs growth rate we have achieved since the recession ended in 2009 is still much lower than the jobs growth rate assumed in the SHMA for the period 2011-2031, during which period it is inevitable we will experience at least one more recession. This comes at a time when the UK is creating more jobs than the rest of the EU put together, so can hardly be described as a normal set of circumstances.

The flawed jobs growth rate in the SHMA adds 5,100 extra houses to to the overall housing allocation to the combined Housing Market Area of Hart, Surrey Heath and Rushmoor. The impact of this is that it pushes up Hart’s own allocation and forces Surrey Heath and Rushmoor to ask Hart to become a sink for 3,000 extra houses for them. Furthermore, these jobs forecasts lead to over-estimates of the amount of employment land we need and so constrains the amount of land that might be made available for housing.

Hart becomes Housing Sink for Surrey Heath and Rushmor

Hart becomes sink for 3,100 houses from Surrey Heath and Rushmoor

If these errors in the SHMA growth rate were corrected the threat from Surrey Heath and Rushmoor would evaporate and Hart’s own housing allocation for the Local Plan would come down from 7,534 to around 6,750, which would definitely mean the remaining requirement could be made from brownfield sites alone.

How long before the penny drops with Hart District Council and the other Hampshire boroughs that they need to revise the SHMA to a more realistic number?

Ranil says no to Winchfield new town and yes to brownfield

Posted on October 6, 2015October 15, 2015

Ranil Jayawardena says no to Winchfield new town and yes to brownfield development

In a very welcome move, local MP for Hampshire North East, Ranil Jayawardena has come down strongly against proposed large scale green field developments such as Winchfield New Town, and asked Hart Council to produce a register of brownfield sites and be more active in using Compulsory Purchase Orders (CPOs) on brownfield sites that are suitable for housing.

In a week where Conservative MP’s have been spat at on the streets of Manchester, I think the only risk to Ranil after publishing his article is that he will be showered with kisses from his local constituents.

In response to questions from his constituents, Ranil has set out his views on planning and development. Ranil has also set up a petition saying brownfield development must be more strongly prioritised by Local Planning Authorities and Neighbourhood Plans must continue to be respected, both in the absence of Local Plans and by Local Planning Authorities when devising Local Plans.

Sign Ranil's Petition

The key passage from Ranil’s article is re-produced below:

I believe unused and redundant commercial buildings should be brought forward for regeneration before any more greenfield sites are allocated anywhere in North East Hampshire. That includes Grove Farm, Hop Garden, Winchfield, the Urnfield – and any other greenfield site for that matter – unless a locally-led Neighbourhood Plan wants to build homes to meet local needs.

I’ll go further. 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. This has the massive advantage of, often, improving an area; instead of vacant office buildings on Fleet Road, for instance, why not have modern apartments for young professionals who can’t otherwise buy a home in our area?

In July 2015, the Chancellor set out in the budget that, to reinforce our commitment to making best use of brownfield land, legislation will grant permission in principle for housing on suitable sites identified in the new statutory brownfield register. (Interested folk might recall that Hart District Council was previously asked to create a register, but chose not to. There will now be one.) Brownfield redevelopment will also be supported by strengthened advice for authorities on the release of land earmarked for employment purposes where it is no longer needed. Whatever your politics, I hope you’d agree that the Government – while still protecting the rights of local Councils to determine the future of their own area – is being clearer than ever that brownfield land must be prioritised.

I’d even suggest, perhaps unusually for a Conservative, that Councils should be more active in their use of Compulsory Purchase Orders (CPOs) where brownfield sites exist and it is clear that it would be a good site for housing, but the landowner is standing in the way of development, or the site as a whole is currently in multiple ownership. Not only would this deliver properly thought through regeneration, maximising the potential of brownfield land but, done right, it would also be good for local taxpayers, as the receipts from such a scheme on the eventual sale or rental of properties would help to keep Council Tax low in future…

Of course, the National Planning Policy Framework has always made clear that “planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land)” and that local Councils “may continue to consider the case for setting a locally appropriate target for the use of brownfield land”. I’ve spoken with Government Ministers and others about this policy, which applies across the country. I was pleased that the Prime Minister included a £1billion ‘brownfield regeneration fund’ in the Conservative Party manifesto, which will help make more brownfield regeneration happen, while now requiring Councils to bring forward 90% of suitable brownfield sites for housing by 2020, both of which will help protect our countryside.

Needless to say, We Heart Hart is delighted by Ranil’s article as it reiterates many of the points we have been making for some time about brownfield capacity and the need to establish a proper database of brownfield sites as part of a different approach to the local plan.

It remains to be seen whether Hart District Council’s Conservative administration will heed the advice of its local Conservative MP and the express wishes of the Conservative Government when preparing the forthcoming coming consultation paper on housing options for the Local Plan.

Of course, Ranil’s intervention also increases the pressure on Rushmoor Borough Council who are needlessly protecting 96 hectares of brownfield land when there is a massive surplus of employment land whilst at the same time asking Hart to build 1,600 houses for them.

Local NHS budget gap of £47m per year adds extra pressure to infrastructure funding

Posted on October 4, 2015October 4, 2015

Frimley Park Hospital

Get Hampshire has reported that Leaders of the North East Hampshire and Farnham Clinical Commissioning Group (CCG), the body responsible for the NHS in our area, have said that demand for services is rising much faster than their budgets and that in five years time there will be a funding gap of £47m per year.

This comes on top of Hampshire County Council’s £1.9bn infrastructure funding gap and Hart’s own £78m budget shortfall. We have estimated the costs of the infrastructure required for a new town at £300m, based on Hart’s own ideas of what new infrastructure will be required compared to around £40m that might be expected as developer contributions.

It is simply astonishing that as part of the Local Plan, Hart District is being asked to build over 7,500 houses and Rushmoor Borough Council over 9,800 houses (Rushmoor itself has an £80m funding gap) to increase congestion and add even more pressure on infrastructure and health services when it is clear that there simply isn’t enough money to fund even current demand let alone the new demands from the extra housing.

This is contrary to 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”

Surely it is time to put a moratorium on any further major developments unless and until the infrastructure funding issues are resolved.

Hart Council rejects opinion of 2,130 people who signed the We Heart Hart petition

Posted on October 2, 2015October 2, 2015

Hart in Heart of Hart, Winchfield, Hart District, Hampshire

Hart in the Heart of Hart, Winchfield, Hampshire

We went to the Cabinet meeting last night armed with a draft of Hart Council’s response to the petition and unfortunately, the council rejected the three main elements of petition to reduce the overall housing allocation for Hart and our demand that the remaining housing allocation is met from brownfield sites alone. The council also refused to stop planning to build a new town that would act as a sink for 3,100 houses from Rushmoor and Surrey Heath.

It is outrageous that Hart Council should dismiss the opinion of 2,130 people. Hart’s own consultation only received 750 replies and only 202 of those expressed a preference for a new town. Given the earlier failure of the Local Plan at inspection, it is simply astonishing that Hart should be basing their planning policy on a “guesstimate” of brownfield capacity. It is unbelievable that they refuse to set up a proper register of brownfield sites and can’t be bothered to track which brownfield sites have been granted planning permission.

We have produced a press release about this that can be downloaded from the link below:

We Heart Hart Press Release 2 October 2015

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Hart becomes sink for 3,100 houses from Surrey Heath and Rushmoor

On a more positive note, the council did say they would consider the vision we put forwards and will include a new vision in the forthcoming consultation. The council did also say they would try to accommodate the needs of the elderly, but implied they could only do so if they built a new town at Winchfield. It is clear the council has no means of measuring its performance against the SHMA requirement to build 2,500 specialist units for the elderly.

The debate at council raised a number of interesting points, but Cabinet did not resolve to alter anything in the draft response they had put forward and clearly had not fully considered our suggested response to the petition. In effect, the council are ignoring the views of 2,130 people on several of the key issues raised by the petition. We will have to mobilise our supporters to put forward their views in the forthcoming consultation.

The detail of the discussion covered a number of topics:

Challenging the SHMA. The council did concede that they would need to re-visit the SHMA in due course and update the employment forecasts. We did point out that the jobs forecasts assume a growth rate nearly double that we achieved in the period 1998-2012, and that Cambridge employment forecasts for the South East used in a challenge to the Vale of White Horse Local Plan are similar to historic average growth rates we beleive should be used in the SHMA.

The council refused to undertake a study to quantify the value of Hart’s environment and ecology. This is a blow as it could enable the council to use environmental constraints as an argument for not building the full housing allocation.

Brownfield sites. Despite putting evidence in front of council that there is brownfield capacity for at least 2,438 dwellings and possibly over 3,600 units, Hart is still sticking by its current “guesstimate” of only 1,800 units on brownfield sites. It is quite astonishing that Hart is basing its planning policy on a “guesstimate”. Last week Hart Council did admit that there was a residual requirement of only 2,900 houses. It is clear to us, that meeting the the remaining need from brownfield only is well within reach.

Some councillors were concerned about our proposed densities in urban areas until we pointed out that they have already approved and are delivering developments at even higher densities. Other concerns raised were about using up too much employment land until we pointed out that there’s over 500,000 sq m of vacant employment land across the housing market area, and we are in no danger of running out any time soon.

Overall I am afraid I got the impression that they listened, but they had already made their mind up that a new town was the answer to the Local Plan no matter what contrary evidence was put to them.

We must gird our loins for a long campaign to fight against these proposals.

Power over the Hart Local Plan concentrated in urban councillors

Posted on October 2, 2015October 2, 2015

Hart District Council Offices

It has emerged from answers to Winchfield Action Group’s questions at last week’s Hart District Council meeting that the Hart Local Plan Steering Group (LPSG) is made up largely of urban councillors and all of them voted in favour of keeping Winchfield as the only new settlement option for testing back in November 2014. The full Q&A can be found here. The question and answer about the composition of the LPSG is shown below:

Question 2

Could the Council confirm who are the members of the core strategy team in HDC, both elected and officers, who are formulating the Local Plan and their respective responsibilities?

SP response

Local Plan Steering Group comprises:

Cabinet Member for Planning (Chairman) Stephen Parker (Con)

The Leader of Council As above

Cabinet Member for Housing Stephen Gorys (Con)

Chairman of Planning Committee Simon Ambler (CCH)

Political Group Leaders David Neighbour (Lib Dem)

James Radley (CCH)

Officers:

Joint Chief Executive – Daryl Phillips – Project Sponsor

Planning Policy Manager – Daniel Hawes, (supported by a Principal Planning Policy Officer and a Planning Technician) – responsible for delivery of [the] local plan

All of the councillors above, except for Stephen Gorys (Odiham, Hampshire ward), represent urban areas in the district. It is also worth noting that Stephen Parker is council leader, the cabinet member for planning and leader of the Conservative group and so takes 3 of the 7 available positions on the LPSG as just one person.

This looks to us like an unhealthy concentration of power in too few hands and the members of the LPSG cannot be said to be representative of the whole of Hart. Moreover, the Local Plan project is massively behind schedule with more delays announced only last week.

Surely, it is time for the composition of the group to change to bring in more fresh ideas, project management experience and achieve a better balance between urban and rural councillors.