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being revised and likely to reduce the housing need, so why are we being consulted on a housing requirement that is no longer valid?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Housing allocation out of date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.

Hart Council planners “lose” 1,400 homes from brownfield sites

Let's just make up the brownfield numbers

Let’s just make up the brownfield numbers

Back in October 2014, Hart District Council said we had capacity for around 750 new dwellings on brownfield sites.  Since then, a number of new sites were identified through the Stonegate Report and other sites such as Bramshill and Fleet police station came up.  This led the Council to say as recently as October 1, that there was capacity for 1,800 homes on brownfield sites.

However, Hart Council have now published a draft housing options paper on their website that says brownfield capacity is now only 400 units [Update: a later version of the same document now states brownfield capacity as 450 units, although this is lower than the official SHLAA estimates for the same sites].  It seems that over the past six weeks, it seems the planners have “lost” 1,400 houses.

As far as we know very few, if any, of the initial 750 units have been given planning permission since October last year.  We have made a FOI request to get to the bottom of it.

It remains a mystery where they have gone to, but one can only assume that there is a cabal of concrete campaigners in Hart who are determined to build on our beautiful countryside at the same time as they protect vacant and derelict office blocks In Hook, Fleet and all across the district. Please do get involved with this consultation and respond to it using our guide on our dedicated page about this consultation here.

 

CPRE condemns unrealistic housing targets

CPRE Housing Target Merry Go Round

CPRE Housing Target Merry Go Round

In its latest newsletter to members, the CPRE has strongly condemned the system of setting unattainable housing targets as a dangerous flaw in the current planning system which must be changed. It is opening the door to wave after wave of speculative planning applications for housing on greenfield sites across England.

They point out that setting ever higher housing targets only results in housebuilders banking land and cherry picking the most profitable sites to develop, usually on greenfield sites and restricting the build rate to maximise profits. Then local planning authorities get the blame for not building enough housing and have to allocate even more land.

We agree strongly with the CPRE’s stance, and ask you to consider if you would like to become a member of CPRE to help fund their efforts.

 

Housing targets systematically over-stating housing need

Is this what we want Hart to turn into?

Is this what we want our countryside to turn into?

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

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

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

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

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

 

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

 

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

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

The SHMAs on which this analysis is based are:

Hart, Rushmoor and Surrey Heath, here.

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

East Hampshire, here.

Waverley, here.

Berkshire, here.

Oxfordshire, here.

 

 

Hart Council Leader stonewalls questions about revisions to the SHMA

Hart District Council Offices

Hart District Council Offices in Fleet, Hampshire

Regular readers may remember that we put a number of questions to the Hart Council meeting on 29 October about changes in household, population and jobs forecasts that should be incorporated into the revised SHMA.  All of these questions were met with a wall of silence and peremptory answers.  The Q&A can be found on the council website, with the relevant questions and answers re-produced in full below.

We have not yet received an answer from the Joint Chief Executive to back up his assertion that the brownfield capacity of the district is only 1,800 units.

Question: 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?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

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

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: 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%

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: 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?

Response: A revision of the SHMA is currently under way and this document is part of the evidence base which will inform the assessment. I do not intend to anticipate the result of the assessment of this and other evidence.

Question: 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?

Response: Section 99 of the Housing and Planning Bill which provides for the reserve powers for the SoS at DCLG to recover a local plan does not have any dates. The operative wording is “if the Secretary of State thinks that a local planning authority are failing or omitting to do anything it is necessary for them to do in connection with the preparation, revision or adoption of a development plan document”. The Joint Chief Executive, who is the planning lead on the District Councils Executive network, has ascertained that provided that councils are making reasonable progress towards a local plan, the SoS does not intend to intervene. The powers are intended for a small minority of councils who are making little or no effort to establish a plan. I have independently validated this with my own contacts on the Environment, Economy and Housing Board at the Local Government Association among others. We therefore don’t think the Government will intervene if we meet our new timetable given we will already be at examination in the Spring of 2017.

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.

 

Fog descends on the Hart Local Plan

Fog descends on Hart Local Plan

Fog descends on Hart Local Plan

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

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

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

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

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

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

Ranil emphasises the need for infrastructure alongside housing

Ranil Jayawardena at a brownfield site

Ranil Jayawardena at a brownfield site in Hampshire

Local MP, Ranil Jayawardena has published a new article re-stating his preference for brownfield regeneration and emphasising the need for proper infrastructure to be delivered alongside housing and calling on local councils to take a more active approach.

This is the key passage from his article:

This is an important point. It is clear to me that infrastructure improvements are an absolute necessity for any development – and Government has a role in this part of the equation.

Whether brownfield or greenfield, infrastructure is critical to ensure that these developments not only provides homes for our friends and children, but are taken as opportunities to improve the way of life for existing residents. Whether brownfield or greenfield, development should not come before infrastructure.

I welcome the Hampshire Combined Authority proposal, specifically a ten-year Transport Investment Fund to be used to significantly improve our roads and public transport. This is a good start, but to plan our future, we must consider the past. We should be thinking about the existing infrastructure deficit also and how this can now be mitigated, so that existing residents end up with a better deal.

It is only right that infrastructure is delivered alongside any new development, rather than leaving communities hoping for improvements in the future, when our roads are already jammed and our trains are already crammed.

Ranil also calls on Local Authorities to take a more active role in developing their areas, by actively considering Compulsory Purchase Orders and using development profits to fund additional infrastructure:

There is another way to fund infrastructure, of course. If regeneration is led by local government, through its ownership of the land (whether by private treaty or CPO), the profit that local government makes from the redevelopment can be invested in infrastructure or for the benefit of taxpayers. This is particularly important with brownfield sites, since sites may not be viable – after taking into account a developer’s profit – if they are also required to pay CIL/s106 at the normal level and it would not be good to see large-scale brownfield regeneration without any infrastructure improvements.

Through this vision of active local government, brownfield regeneration genuinely benefits local people, rather than shareholders of a developer, through improved infrastructure and lower Council Tax.

I should probably say that I accept, often, brownfield sites are not in common ownership and, even if they are, the landowner doesn’t wish to develop them. To my mind, however, that is not a reason for brownfield to be put in the ‘too difficult’ pile. Rather, I believe local government has a role to outline how it wishes to comprehensively improve the existing built environment, through purchasing and redeveloping land if not already in its ownership

We wholeheartedly welcome Ranil’s new intervention and we can only hope that Hart District Council are listening. We urge you to sign Ranil’s petition using the button below.

 

Sign Ranil's Petition

 

 

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