CCH reveal plan to Completely Concrete Hart

Posted on November 18, 2017November 18, 2017

CCH reveal plans to Completely Concrete Hart

Community Campaign Hart (CCH) have revealed their plan to Completely Concrete Hart by sticking to the ridiculous 10,185 housing target in the draft Local Plan. This comes despite the new Government method for calculating housing need results in a much lower housing target for Hart, Rushmoor and Surrey Heath.

It is time to up the pressure on CCH to come up with a strategy to take account of this new information. They should build a Local Plan that is good for the whole of Hart that everybody can live with. It is time to drop their plan to Completely Concrete Hart.

To be clear, in our view, Hart’s housing target should be reduced to around 6,500, to take account of the new Government approach, plus a few hundred for Surrey Heath. Using the figures in the draft Local Plan consultation (para 104), this would leave 906 new houses left to plan for. This could be made up from

Sun Park (320), from Local Plan para 109
Grove Farm (423), sadly
The forthcoming Rawlings depot site in Hook (123)
The remaining 40 can come from any number of brownfield sites for instance:
- Hartley Wintney (Nero Brewery – 10)
- Winchfield (Winchfield Court extension – 17)
- The derelict eyesores on Fleet Road – up to 200.

We can save Hartland Village (Pyestock) for the 2030’s.

The revelations came in a reply to an email sent to CCH by a concerned correspondent on Facebook. We reproduce the question, James Radley’s answer and our commentary in red below.

Question to Community Campaign Hart (CCH)

I write to you ask a question about your party’s policy towards supporting (or not) a reduced housing total for Hart District. Specifically, in regard of this statement on the We Heart Hart (WHH) Facebook page:

If Hart followed the latest Government approach to calculating housing need, even Hartland Park wouldn’t be needed. The remaining housing need could be met from Sun Park and any number of other small brownfield sites.

Answer from CCH revealing commitment to Completely Concrete Hart

I am probably the best placed to explain the CCH position on housing numbers. It is true that as a rule we do not engage in social media debates, mainly due to a lack of time. As well as trying to fit in my day job I also expect to spend over 6 hours in total in the council offices today and similarly tomorrow.

One has to ask why the council Deputy Leader and portfolio holder for Services is spending quite so much time in council offices working on the Local Plan. One would hope this time would be put in by the portfolio holder for planning, Lib Dem councillor Graham Cockarill. It obviously takes a lot of effort to Completely Concrete Hart.

Social media debates are very time consuming in order to stay on top of all the posts and then the debate tends to descend to the lowest common denominator. I for one would certainly rather put the time and effort in where it matters and unless one is going to invest all that precious time in the social media arena, better not to engage at all.

This sounds like CCH want to stay in their own bunker and not actually engage with anyone who disagrees with them. They are afraid to engage because they don’t have any facts or arguments to back up their new town ideology.

Unfortunately WHH are wrong in their assessment of housing numbers.

No, we are not wrong in our numbers. Here is the relevant section of the Government consultation document.

Para 15 of Planning for the right homes in the right places

Working through this. The demographic baseline is the latest DCLG household projections (Table 406) that can be found here. These show that over the period 2011-2032, Hart requires 218 dwellings per annum, or 4,536 in total. In the reference period of 2016-2026 used by the Government, Hart requires 209 dwellings per annum. This 209 dpa is then modified to account for market signals and results in a new Government figure for Hart of 292 dpa. Scaling up to the full planning period results in 6,132 new houses for Hart. And that’s it. No more further adjustments for changes in household size. No more houses for people we have to import who then go and work in London. This compares to the 8,022 in the SHMA and 10,185 in the draft Local Plan.

Hart housing targets under alternative scenarios

They are citing a baseline figure in a government consultation paper which is not part of the planning policy framework in effect at this point in time and is a figure which even if it was policy is taken as a starting point on top of which other factors will add to the housing numbers needed.

We have answered the point about the baseline above. The baseline is the demographic projection. The Government then already made the upwards adjustment for market signals in the 292 dpa figure. It is true that these figures are so far only part of a consultation paper, but the feedback we have received is that the Government is committed to pushing these through. It would seem prudent to us for Hart to take these figures into account now and prepare a Local Plan with two scenarios:

The first scenario should be based upon the 6,132 outlined above. Plus a few hundred to give some flexibility to build some new houses for Surrey Heath. They may still have a problem meeting their new, lower housing target. This would give a total of around 6,500.
The second scenario should be based solely on the SHMA figure of 8,022.

To be clear, the daft 10,185 target in the draft Local Plan should be dropped forthwith. Even James Radley admits the extra 2,000+ houses on top of the SHMA won’t affect house prices. As the Government position becomes clear, Hart can make the decision on which scenario can be submitted to the inspector. There is no need to Completely Concrete Hart.

We lost the fight against Grove Farm because we don’t have a local plan in place. We don’t have a local plan because the Conservatives have allowed it to drift for years in a sea of procrastination driven by their internal in fighting.

True, Grove Farm was lost because we don’t have a Local Plan. It was also lost because our policies are out of date and because the application was not determined on time. Yes, the Tories missed all their own deadlines. But CCH have also played their part by forcing a delay in the Local Plan last December.

The main reason for taking control was to get the local plan out and to do so by a total focus and not letting the intentional disruptions from WHH to deflect us from that.

At no time have we sought to delay the Local Plan. We Heart Hart first highlighted the project management and governance problems back in April 2015 and again in January 2016 after the consultation omnishambles.

It is quite clear that if we don’t get a local plan out that is based on realistic and future proof housing numbers, then Fleet & Church Crookham will continue to be blighted by bolt on developments such as Grove Farm, Pale Lane and whatever is next.

Yes, we need a Local Plan. And quickly. The realistic numbers to use are the Government’s new numbers. These are already future proofed by the extra houses to take account of market signals. We have suggested a modest further uplift to help out Surrey Heath.

It is interesting that the Deputy Leader for the whole of Hart is only concerned about Fleet and Church Crookham. We are also concerned about Owens Farm to the west of Hook. We are also concerned about the long term impact of adopting a ridiculously high housing target. This will then be compounded for decades to come, putting even more of our green fields under threat, including Pale Lane and Crookham Village.

WHH know this and are trying to undermine the new settlement option in the full knowledge that they are condemning us to yet more incremental developments which do not produce any retrospective infrastructure.

We are opposed to the new settlement because we don’t believe it is needed. And we certainly don’t believe it will solve the infrastructure problems facing the district. And we don’t want to Completely Concrete Hart. If we adopt the new Government housing numbers, it will be better for everyone.

I hope that my brief explanation helps.

It does, but not in the way he thinks. It confirms CCH is in the driving seat, dragging the Lib Dems along with disastrous policies to Completely Concrete Hart. The explanation confirms CCH is in a bunker, unwilling and unable to debate the real issues. CCH is locked into its new town ideology and is trying to justify it by sticking to a ridiculous housing target.

Hart squanders £110K on doomed Grove Farm appeal

Posted on November 14, 2017November 13, 2017

Grove Farm Appeal - Netherhouse Copse Site Layout

£110K squandered on Netherhouse Copse – Grove Farm appeal

It has come to light that Hart spent nearly £110,000 on lawyers and consultants in the course of defending the doomed Grove Farm appeal.

Regular readers may remember that the council failed to answer our questions about this at the last council meeting. However, a recent FOI request from a concerned resident has finally turned up some answers.

In total the council spent £109,858.59 on external legal and consultant costs. Astonishingly, Hart Council does not seem to track the time spent by its own staff on such matters and can’t tell us the costs incurred by internal officers. The good news is that it seems the developer did not press to be awarded its own costs of running the appeal.

However, it appears as though the council did not seek an external view on the chances of success of the appeal. We said back in December 2016 that the failure to determine the application would lead to an appeal and that Hart would likely lose the appeal.

£110,000 represents about 1% of Hart’s spending budget, and they are strapped for cash. Even though we oppose the Grove Farm development, we don’t think the council should be wasting money trying to fight lost causes.

Full FOI request on Grove Farm appeal costs

The full questions and answers (in red) are shown below:

Can you please set out the cost of defending the appeal including:

a) External legal and consultant costs: The Council holds the information that you seek. The costs were £109,858.59.

b) Internal time costs of officers. The Council does not hold the information that you seek.

c) Any potential loss of New Homes Bonus. The Council does not hold the information that you seek.

d) Lost time on the Local Plan due to resources being diverted to defend the appeal. The Council does not hold the information that you seek.

e) Appellant costs. The Council does not hold the information that you seek

Did the council receive legal advice on the chances of success in defending the appeal? The Council does not hold the information that you seek
a) What, in summary, did the advice say? The Council does not hold the information that you seek.

b) Will you make the advice public? The Council does not hold the information that you seek

c) Was the provider of this legal advice the same organisation that helped
defend the appeal? The Council does not hold the information that you seek

d) How much did the advice cost? The Council does not hold the information that you seek

Why the 10,185 ridiculous housing target is a bad idea

Posted on November 12, 2017November 11, 2017

Why the 10,185 ridiculous housing target is a bad idea

We challenged a number of groups who did not oppose the ridiculous housing target. This led to one of the accused groups saying we were spreading “negative waves, man”. We think it is very negative to support the 10,185 housing target, but were surprised that many did not understand the full impact. This post aims to explain why the housing target in the draft Hart Local Plan is such a bad idea.

This analysis shows that, given the way Government household projections are calculated, if we continued to follow the 10,185 target in the Local Plan, the compounding effect would mean we end up building over 12,000 houses. However, if we followed the new Government methodology, we would end up building around 8,200 new houses, which could be accommodated on brownfield sites.

The only possible reason to continue with this ridiculous housing target is CCH’s ‘new town at all costs’ ideology that will end up destroying what all most love about living in Hart district.

The detailed analysis is shown below:

How are the Government household projections calculated

The primary driver of household projections is the ONS population forecast.

Methodology for calculating DCLG household projections

The sub-national population forecasts are in turn calculated as follows (emphasis mine):

Data for up to 6 preceding years are used, so for the 2014-based projections trends were based on data from the years 2009 to 2014. The projections based on these trends are constrained to the assumptions made for the principal 2014-based national population projection for England.

….

The civilian population from the previous year is then aged-on, local fertility and mortality rates are applied to calculate projected numbers of births and deaths, and the population is adjusted for internal (movement between areas within England), cross-border (movements between England and the other countries of the UK), and international (movements between England and countries outside of the UK) migration.

Impact of higher migration into Hart from other districts

We know that the SHMA is already planning for more houses than we need, and the SHMA itself acknowledges that these extra people will come from other districts. Hart have then compounded this problem by planning for 2,000 more houses than the SHMA calls for.

The impact of planning for more houses than we need is that inward migration is artificially inflated and then used in later years to inflate the future housing requirement even further. This is compounded each time the population and household projections are made. Remember also that Local Plans are supposed to be reviewed every five years and the revised household forecasts taken into account.

Hart housing target model

We have done some simple modelling to illustrate the impact of this over the plan period. This is illustrated in the data table below:

Hart housing requirement data table

The table shows four baseline numbers for 4 different scenarios:

The raw 2014-based DCLG household projections which give a total of 4,586 new houses over the plan period
The new Government methodology, using their rate of 292 per annum from 2016-2026 over the whole plan period of 2011-2032. This gives a total of 6,132.
The SHMA, which gives a total of 8,022
The ridiculous 10,185 in the draft Local Plan

The first thing to note is the draft Local Plan figure is more than twice the raw household projections. The second point to note is the figures in the new Government methodology already include a 40% ‘market signals’ uplift over the raw household forecasts. This is because Hart’s house prices are very expensive compared to local earnings.

However, these numbers are not the end of the matter, because the Local Plan has to be reviewed every five years. We have modelled what might happen in 2021 and 2026 under two scenarios. When we get to 2021, the DCLG household forecasts will look backwards at the rate of population and household growth from 2016 to 2021 and project this rate of growth forwards. Similarly, in 2026, the forecasts will project forwards the 2021-2026 rate of growth.

Hart housing target using new Government methodology

Hart housing requirement using new Government methodology

Under the first scenario, we have assumed that Hart builds at the rate of 292 per annum from 2016 to 2021. This rate of growth won’t have any impact on house prices, unless there is a significant recession. So, house prices will still be very high compared to earnings. Even James Radley agrees with this. Therefore, the ‘market signals’ upwards adjustment will apply again. This will inflate the required build rate. Similarly, in 2026, the 2021 build rate will then be further adjusted. This will result in a total build in the period 2011-2032 being 8,239. This is slightly more than is in the current SHMA.

Hart housing target using Local Plan figures

Hart housing requirement using Local Plan figures

Under the second scenario, we have started with the 485 build rate in the Local Plan. We then made adjustments in 2021 and 2026 as above. The result is that the total build in the period 2011-2032 will be 12,185 units. Or 2.6 times the baseline household projections.

This is clearly an unsustainable proposition. We must reject the current Local Plan target and use the new Government figures as soon as possible. The only possible reason to continue with this ridiculous housing target is CCH’s ‘new town at all costs’ ideology that will end up destroying what all most love about living in Hart district.

Winchfield new town – EIA requested by developers

Posted on November 5, 2017November 5, 2017

Developers request EIA Assessment of Winchfield New Town

Developers request screening opinion EIA Assessment of Winchfield New Town

Barton Willmore have submitted an application for an Environmental Impact Assessment screening opinion on Winchfield New Town (aka Garden Community). The application can be found here and searching for application number 17/02592/EIA.

As far as we can tell, the proposed site directly abuts the proposed Pale Lane (Elvetham Chase) development. The proposal is for:

2,000 new dwellings
A new secondary school
Up to 2 new primary schools
Children’s nursery
Two local/neighbourhood centres
4 Ha of employment land
Provision of Suitable Alternative Natural Greenspace

Reasons to oppose Winchfield New Town

As might be expected, we oppose this new development on number of grounds:

Flood Taplins Farm Lane Winchfield 28 March 2016

The site is not in the draft Local Plan, and to change the Local Plan so significantly would require another round of consultation and more delay, putting at risk other sensitive sites such as Pale Lane and West Hook.
Development of this scale is simply not required. The new Government approach to calculating housing needs would result in 6,132 new houses for Hart compared to the unnecessary and ridiculous 10,185 in the draft Local Plan.
The site is totally unsuitable for such large scale development due to flood risk as we documented here (4 Jan) , here (7 Jan), here (9 March on Station Road) and here (28 March due to #StormKatie). The area of Taplins Farm Lane near the railway bridge flooded three times in 2016 alone.
Lack of road infrastructure
Historic Environment
Bio-diversity
Landscape
Water Quality

We suggest that you add your comments by logging on to Hart’s public access system on this link, and searching for 17/02592/EIA.

Goalposts changed in SWR timetable consultation

Posted on November 1, 2017October 30, 2017

South West Trains SWR timetable consultation comparison

The goalposts have been changed in the South West Railway SWR timetable consultation. As you may know already, SWR launched a consultation on the train timetable in late September. However, in response to negative feedback they have revised their proposals.

These new proposals are still unacceptable. Sorry to say this, but even if you have already responded to the first proposals, please respond to these new proposals. Please use the download below to respond to consultation by 22 December 2017. Feedback can be sent to: timetable.feedback@swrailway.com

SWR timetable consultation

Download Now!358 Downloads

Please also sign Ranil’s petition which can be found here.

Impact of South West Railway SWR timetable consultation

The current line to London is already running beyond capacity, and these changes represent a reduction in service at peak hours which cannot be a good idea.

In summary the changes proposed are:

Retains the same number of services from Hook and Winchfield to London, however, many of these services now no longer stop at Fleet and Farnborough
Keeps the same number of Fleet to London services as now
The new proposals result in slightly faster services to London

The impact of these changes will be:

School children and students attending Farnborough Sixth form, Salesian and Farnborough Hill will now have far fewer services to choose from to get from Hook/Winchfield to Farnborough.
This is likely to lead to both over-crowded trains and increased car journeys, leading to more pollution and congestion
No effective increase in capacity from Fleet, Winchfield and Hook to London, even though services are already over-crowded.

Alternative approach to SWR timetable consultation

Thousands of houses have either already been given permission or are proposed in Hart’s Local Plan. These include around 500 dwellings at Sun Park, 1,500 Hartland Village, and 420+ at Grove Farm all near to Fleet station. Moreover, 550 houses are currently being built in NE Hook and 1,800 dwellings are proposed at Murrell Green, both close to both Hook and Winchfield stations. Many hundreds more dwellings are being considered on brownfield sites in Hook. It does seem rather odd that SWR are not proposing to dramatically increase services just at the time when demand is going to increase. I would suggest the following alternative plan:

Ensure that many more of the Hook/Winchfield services stop at Fleet/Farnborough to help our kids get to school
Increase services from Fleet to London
Increase capacity by running more 12-car trains on the whole line at peak times
Reduce the number of first class carriages on 8 and 12-car trains to further increase passenger capacity

Hart Corporate Plan Consultation – please respond

Posted on October 29, 2017January 13, 2018

Hart Corporate Plan: Liberal Democrats David Dave Neighbour in the pocket of Community Campaign Hart James Radley

Hart Corporate Plan: Liberal Democrats in the pocket of Community Campaign Hart

A consultation has been launched on the latest iteration of the Hart Corporate Plan. Whilst this contains some welcome initiatives, there are other developments that are of significant concern.

We rask that you respond to the consultation that can be found here. The deadline is 4pm on 31st October 2017. We suggest you make the following comments:

Communities. Restore the plan to create a Hart-controlled trading company to deliver much needed social housing to the district.
Communities. Drop the idea of delivering more houses than identified in the SHMA, and follow the new Government housing target of 6,132 instead.
Communities: Focus infrastructure spending on the areas most in need: roads, education and healthcare provision. Adopt a Local Plan that minimises the infrastructure funding gap.
Local Economy. Drop the idea to obstruct brownfield development by using Hart controlled SANG to restrict redevelopment of brownfield sites.
Local Economy. Restore the focus on urban regeneration, by appointing a cabinet member with specific responsibility for this area.

Community Campaign Hart dominate Hart Corporate Plan

Anybody who has been to the last two council meetings cannot have failed to notice the domination of Community Campaign Hart (CCH). This is evidenced by:

Council leader passing furtive glances to CCH deputy leader as he answers questions from members.
CCH leader passing notes on how to answer questions to the head of the Planning portfolio.
Submissive body language from Lib Dem cabinet members towards CCH members.

This shows that the changes to the Corporate Plan have been driven by the CCH dominance of the coalition administration.

In particular, the policies to restrict brownfield development, drop the housing trading company and remove the focus on urban regeneration will impact Liberal Democrat voting areas such as Blackwater and Ancells Farm, where they hold both District and County seats.

The Lib Dems should reassert their position and start fighting for policies that will help the areas that vote for them.

Hart don’t know cost of Grove Farm appeal

Posted on October 27, 2017October 26, 2017

Hart Council knows nothing about Grove Farm Appeal

Hart Council have admitted they don’t know the cost of the Grove Farm appeal. They don’t know how much they spent on lawyers and consultants. They don’t cost the internal time costs of Hart Officers. Thankfully, there won’t be any loss of New Homes Bonus and the inspector did not award appellant costs against Hart.

Hart Council is very short of money, and the costs of this appeal must represent a significant proportion of Hart’s spending budget of £9m this year (see budget book p14). It is scandalous that they have no ability to track the costs of such large expenditures.

We warned back in December 2016 that the failure to determine the application would lead to an appeal and that Hart would likely lose the appeal.

It is still highly likely the developers will appeal the decision anyway because the officers recommended approval. Realistically, it is likely Hart would lose the appeal.

Apparently, the Overview and Scrutiny Committee won’t be looking into the decision to defend the Grove Farm appeal. Councillors apparently have no plans to forgo any of their allowance to help replenish public funds.

More worrying, Hart have no plan to avoid being a sitting duck in planning appeals between now and when the Local Plan is finally adopted.

Full questions and answers about Grove Farm appeal

Here is our list of questions and our recollection of the answers in red received at Council on Thursday (answers to be updated when the minutes are published):

Q1: It is of course a highly regrettable that the Grove Farm planning application was granted at appeal. However, given that officers recommended that planning permission be granted and the planning committee failed to make a determination on time, it is not unexpected that the appeal was allowed. Can you please set out the cost of defending the appeal including:

External legal and consultant costs. A lot of words that amounted to “Don’t know”.
Internal time costs of officers. Don’t identify internal costs.
Any potential loss of New Homes Bonus. £0.
Lost time on the Local Plan due to resources being diverted to defend the appeal. Don’t know.
Appellant costs. £0.

Q2: Did the council receive legal advice on the chances of success in defending the appeal? In accordance with the Hart Code of Conduct objectives for openness and transparency, can you answer the following:

What, in summary, did the advice say?
Will you make the advice public?
Was the provider of this legal advice the same organisation that helped defend the appeal?
How much did the advice cost?

Answer: It’s a planning matter so we didn’t take legal advice on the chances of success

Q3: A recent joint Chief Executive statement said “In terms of the impact for planning across the District this appeal decision tells us little that is new. The Inspector used the same reasons that had previously been used by the Inspector at Moulsham Lane”. In accordance with the Code of Conduct statements about “Managing risks and performance through robust internal control and strong public financial management”, will the Overview and Scrutiny Committee be examining the decision to defend the Grove Farm appeal and making recommendations to avoid future waste of public funds?

Answer: Overview and Scrutiny only examine decisions from the Executive, not of committees, so no.

Supplementary: Will councillors and officers who made the decision to proceed with the appeal forego all or part of their allowance or bonus to show solidarity with hard pressed council taxpayers by helping to replenish public funds? No.

Q4: Given the saved policies have been ruled to be out of date twice now, what steps can the council take to avoid becoming a sitting duck in future planning decisions and appeals in advance of the Local Plan being adopted? Lots of words that amounted to “None”.

Hart major planning site update

Posted on October 26, 2017October 23, 2017

Hart Major Planning Site: Planning application submitted for 700 houses at Owens Farm west Hook 17/02317/OUT

Hart Major Planning Site Update

This post will provide a Hart major planning sites update. We will cover:

West of Hook – Owens Farm
Bramshill
Pale Lane (Elvetham Chase)
Hartland Park (Pyestock)
Grove Farm (Netherhouse Copse), Fleet

Hart Major Planning Site: Owens Farm West of Hook

A planning application has been made for 700 houses at Owens Farm, west of Hook. The deadline for comments and objections has been set for 1st November 2017. The application can be found at Hart’s public access system and searching for reference 17/02317/OUT.

Hook Action Against Over-Development have published some excellent guidance on how to respond. This can be found here.

We don’t think this development is either desirable or necessary and would urge you to oppose it.

Hart Major Planning Site: Bramshill

This is the application for around 250 units at the former Police College at Bramshill. This application was turned down in March 2017. However, the developer has appealed and the appeal hearing will be held in the main house starting at 10am on 31st October.

The application can be found at Hart’s public access system and searching for reference 16/00720/FUL.

We support the redevelopment of this brownfield site. In particular, we would like to see Grade I listed main Bramshill House preserved in some way. We recognise that the developer will probably have to make money elsewhere to properly fund the redevelopment. However, we do have reservations about the scale of development proposed elsewhere on the site which is in the SPA.

Hart Major Planning Site: Pale Lane (Elvetham Chase)

Elvetham Chase (Pale Lane)

This is the application for 700 new houses at Pale Lane aka Elvetham Chase. The site lies between Elvetham Heath, the railway and the M3. The controversial planning application was submitted for this site back in November 2016.

We understand that the deadline for determination has been extended to 10 November 2017. There is a Planning Meeting at council planned for 8 November 2017.

The application can be found at Hart’s public access system and searching for reference 16/03129/OUT.

We hope and expect that Hart Council will reject this application. However, we would not be at all surprised if the developer appealed the decision. It would be difficult to defend the appeal after the Grove Farm decision, unless they manage to get the Local Plan in place before the appeal is heard.

Hart Major Planning Site: Hartland Park (Pyestock)

Hartland Park (Pyestock) Master Plan

This is the site of former Pyestock National Gas Turbine Establishment. We have no further update since Hart Council’s planning committee agreed to the principle of building up to 1,500 new homes on this brownfield site.

We agree with this decision in principle, but echo the council’s concern about a number of items:

The developer is proposing only 20% Affordable Housing. We would like to see more affordable housing and especially some social housing for those who can’t rent and can’t buy.
We are concerned about the road network and therefore think Kennels Lane should be upgraded to provide a relief road around the site
There should be a proper cycle/walking route installed to provide easy access to Fleet station.

We will continue to monitor this development.

The application can be found at Hart’s public access system and searching for reference 17/00471/OUT.

Hart Major Planning Site: Grove Farm (Netherhouse Copse)

Grove Farm – Netherhouse Copse Site plan

Sadly, this site was approved for development by the planning inspector. This is an application for 423 new houses on the site off Hitches Lane in Fleet. The appeal for this site was heard back in July.

Please respond to DCLG consultation – Planning for the right homes in the right places

Posted on October 24, 2017October 24, 2017

DCLG Consultation – Planning for the right homes in the right places

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

We have now had chance to compile our answers and submit them to the Government. We encourage others to do so too. We understand that there have been howls of protest coming from the boardrooms of the developers, so it is important that the general public make their voice heard to see off this powerful lobby. You can respond to the consultation on the link below, it takes around 10 minutes if you cut and paste our suggested answers.

Full DCLG Consultation document (Planning for the right homes in the right places)

DCLG Consultation response link Deadline 9 November 2017.

Our suggested responses to DCLG Consultation

Question 1 (a): do you agree with the proposed standard approach to assessing local housing need? If not, what alternative approach or other factors should be considered?

Answer: Yes

Comments:

We broadly agree with your proposals. The main strength is that the approach gives local housing targets that add up in total to the national requirements, thus giving a national consistent and coherent approach. This is in stark contrast to our own Hart Local Planning Authority (LPA) which has created a draft Local Plan to build at 485 dpa, compared to this new approach which arrives at a build rate of 292 dpa. The SHMA carries out a number of dubious adjustments to the baseline population forecast to arrive at a target of 382 dpa. The impact of the higher target would be to concrete over many beautiful green fields, and by definition, import people from other districts, many of which will work outside the area, which is quite the opposite of ‘sustainable’ development.

We challenge that nature of the ‘affordable housing’ uplift. First, there is no evidence that building extra houses will result in lower prices. Certainly not on a scale that would make a material difference to affordability. Houses are assets, and high prices are as a result of ultra-low interest rates and QE.

However, we do agree that there is probably a level of suppressed household formation that needs to be dealt with. Almost by definition, these people can’t afford to either rent or buy. Building more open market (or even ‘affordable’ houses at a 20% discount) is not going to help these people. These people need access to social housing at affordable rents. We therefore suggest that the ‘affordable housing’ uplift that you calculate should be delivered in the form of social housing.

Those who are already renting, but want to buy don’t, by definition, need an extra house to be built as they are already housed. What they need is to save for a deposit. However, we don’t support widespread Help to Buy programmes, since these are likely to end up fuelling higher house prices.

We would also suggest the planning horizon is extended to say 15 years, to cover the time horizon of many Local Plans.

We would also suggest that you ask LPAs to break down the housing need into size (e.g. number of bedrooms) and type (e.g. specialist accommodation for the elderly, self-build).

Question 1(b) how can information on local housing need be made more transparent?

Comments:

Ask Local Planning Authorities (LPA) to publish the ONS figures for future population growth in an easily digestible form; publish data on suppressed households and affordability ratios.

It would also be helpful if LPAs were asked to publish data on unimplemented planning permissions, by age since planning permission was granted. There needs to be pressure put upon developers to actually build the houses that have been permitted. A recent House of Lords report indicated that 100,000 fewer homes were being built each year than were being permitted.

Question 2: do you agree with the proposal that an assessment of local housing need should be able to be relied upon for a period of two years from the date a plan is submitted?

Answer: Yes

Comments:

LPAs need a sensible period of stability. Two years sounds about right. It might be desirable to extend it to three years, so LPAs have at least one year’s grace from when new figures are published to adjust their Local Plans accordingly.

Question 3: do you agree that we should amend national planning policy so that a sound plan should identify local housing needs using a clear and justified method?

Answer: Yes

Comments:

The current SHMA process is flawed. Typically, they are produced for a Housing Market Area (HMA) made up of several LPAs. The only consultees are industry insiders who have a vested interest in pushing up the housing numbers in areas that are profitable to develop, but not in line with local needs.

Once a particular Local Plan comes to examination, the developers bring along highly paid consultants and barristers to argue for even higher numbers. The housing target becomes effectively unchallengable because of the impact it would have on other LPA’s in the HMA.

This national approach is consistent and coherent at national and local level. This would have the impact of limiting housing targets to actual local needs and cutting out lots of cost and time from the process which will benefit everybody (except highly paid consultants and lawyers).

Question 4: do you agree with our approach in circumstances when plan makers deviate from the proposed method, including the level of scrutiny we expect from the Planning Inspectors?

Answer: Yes

Comments:

Again, this approach will cut time and cost out of the process and reduce the scope for developers and their advisors to spend thousands trying to push up housing numbers unnecessarily.

Question 5(a): do you agree that the Secretary of State should have discretion to defer the period for using the baseline for some local planning authorities? If so, how best could this be achieved, what minimum requirements should be in place before the Secretary of State may exercise this discretion, and for how long should such deferral be permitted?

Answer: Not sure

Comments:

Question 5(b): do you consider that authorities that have an adopted joint local plan, or which are covered by an adopted spatial development strategy, should be able to assess their five year land supply and/or be measured for the purposes of the Housing Delivery Test, across the area as a whole?

Answer: Not sure

Comments:

Question 5 (c): do you consider that authorities that are not able to use the new method for calculating local housing need should be able to use an existing or an emerging local plan figure for housing need for the purposes of calculating five year land supply and to be measured for the purposes of the Housing Delivery Test?

Answer: Yes

Comments:

There ought to be some sort of maximum deviation from the new method that can be allowed.

Question 6: do you agree with the proposed transitional arrangements for introducing the standard approach for calculating local housing need?

Answer: Yes

Comments:

Your proposals look fine. However, the Table 1 and para 54 are expressed in very complex sentences with complex and/or conditional statements in both the Plan stage definition and transitional arrangements.

For instance, what constitutes ‘publication’ is this Reg 18 or Reg 19 consultation.

It appears as though you wish to implement as quickly as possible, however, you should make the language clearer. In particular, you should make clear what LPAs whose housing targets have gone down compared to the SHMA or draft Local Plan, what housing target to use. This is especially true when the planned submission date is around March or April 2018. You should also commit to a date for publication of the new NPPF.

Question 7(a): do you agree with the proposed administrative arrangements for preparing the statement of common ground?

Answer: Yes

Comments:

The problems you identify around Duty to Cooperate have affected Hart LPA. Their plan was failed at the last moment, on DtC grounds, back in 2013. Since then it has operated without a Local Plan and is subject to speculative applications.

So, being more specific and transparent around what needs to be done to demonstrate cooperation can only be a good thing, and a Statement of Common Ground sounds like a useful tool.

Question 8: do you agree that the proposed content and timescales for publication of the statement of common ground are appropriate and will support more effective co-operation on strategic cross-boundary planning matters?

Answer: Yes

Comments:

Broadly agree, with the following extra suggestions:

It should be possible for LPAs to go to the Inspector at an early stage of the plan making process to get a steer on the draft of their Statement of Common Ground, to avoid it being failed at examination.

There should be defined timelines for SoCG’s to be kept up to date (say every five years) after plans are adopted, as part of the natural plan updating process

Question 9(a): do you agree with the proposal to amend the tests of soundness to include that:

plans should be prepared based on a strategy informed by agreements over the wider area; and
plans should be based on effective joint working on cross-boundary strategic priorities, which are evidenced in the statement of common ground?

Answer: Yes

Comments:

Question 9(b): do you agree to the proposed transitional arrangements for amending the tests of soundness to ensure effective co-operation?

Answer: Yes

Comments:

Question 10(a): do you have any suggestions on how to streamline the process for identifying the housing need for individual groups and what evidence could be used to help plan to meet the needs of particular groups?

Comments:

There are already mechanisms for defining the size of houses by number of bedrooms and housing for special needs (e.g. specialist accommodation for the elderly) in the SHMA process. It would be most helpful to use these.

It would also be helpful to identify the quantum of social housing requirements. This could be done by estimating ‘suppressed households, and examining local authority housing waiting lists.

Question 10(b): do you agree that the current definition of older people within the National Planning Policy Framework is still fit-for-purpose?

Answer: Yes

Comments:

Question 11(a): should a local plan set out the housing need for designated neighbourhood planning areas and parished areas within the area?

Answer: Yes

Comments:

However, the total of the neighbourhood planning areas added together should be the same total as the overall LPA. There needs to be safeguards that Neighbourhoods are not forced to build many more houses than the formula you put forward in 10(b) against their will.

Question 11(b): do you agree with the proposal for a formula-based approach to apportion housing need to neighbourhood plan bodies in circumstances where the local plan cannot be relied on as a basis for calculating housing need?

Answer: Yes

Comments:

This approach will effectively force already built up areas to increase density and bring forward brownfield sites for development. This can only be a good thing, as it will:

Probably decrease average property size, and thus reduce prices making it easier for younger people to get on the housing ladder
Act as a spur for redevelopment of run down town centres as more people live there, leading to more demand for local shops, cafes, restaurants and cultural venues
Protect green areas on the fringes of built-up areas as amenity space.

Question 12: do you agree that local plans should identify the infrastructure and affordable housing needed, how these will be funded and the contributions developers will be expected to make?

Answer: Yes

Comments:

The proposals should go further and include a post-hoc analysis of the actual performance of a site in terms of sales revenue and profit achieved by developers. Where this is significantly above the planned revenue and profit in the viability statement, then developers should be mandated to make some of that additional profit available for additional infrastructure contributions to roads, schools, cultural venues etc.

Question 13: in reviewing guidance on testing plans and policies for viability, what amendments could be made to improve current practice?

Comments:

The proposals should include a post-hoc analysis of the actual performance of a site in terms of sales revenue and profit achieved by developers. Where this is significantly above the planned revenue and profit in the viability statement, then developers should be mandated to make some of that additional profit available for additional infrastructure contributions to roads, schools, cultural venues etc.

You might also consider re-adopting Garden City principles where land vendors made contributions to infrastructure. This could be achieved by levying a ‘planning gain’ charge on those who sell agricultural land valued at say £2,000/acre on with planning permission at £2m/acre. This pushes up costs for developers and the land vendors make a large windfall. A levy on this windfall could help fund vital infrastructure.

Question 14: do you agree that where policy requirements have been tested for their viability, the issue should not usually need to be tested again at the planning application stage?

Answer: No

Comments:

The level of viability testing that can be carried out at the plan making stage will be very limited. Moreover, a significant amount of time may pass between the plan being made and the application coming up for determination.

Many things could change in the meantime such as the cost of the land, the number and style of the units proposed on the site, the build costs and the infrastructure requirements of the LPA.

It is therefore appropriate that viability is tested again at the point of application, and again once the site is built out, and it can be seen what level of profit the developer has made.

Question 15: how can Government ensure that infrastructure providers, including housing associations, are engaged throughout the process, including in circumstances where a viability assessment may be required?

Comments:

A good start would be to mandate County authorities to extend their timelines for planning school places. For instance, Hampshire’s school planning goes out to 2021, yet Hart’s Local Plan has to be produced up to 2032. These are clearly misaligned and this issue needs to be fixed.

A similar argument should be applied to authorities responsible for roads and healthcare. They should be able to model the overall impact of extra housing within and across LPA boundaries, and make better, more timely assessments of the additional capacity required. This will enable better arguments to be made to demand higher payments from developers.

Question 16: what factors should we take into account in updating guidance to encourage viability assessments to be simpler, quicker and more transparent, for example through a standardised report or summary format?

Comments:

It should be possible to create a standardised land appraisal model, including land costs, build costs, number of units, average net selling price, overhead costs and CIL/S106 contributions. The sensitivity will be around the discount rate used in any NPV calculation, which will vary developer by developer dependent upon their cost of capital.

However, it should be possible to come up with a baseline solution that most can agree on for assessing viability. But as stated above, this should be revisited at planning application stage and post-hoc after the development has been completed.

The building industry produces average costs for different types of dwellings, land prices house prices are available from the Land Registry.

Question 17(a): do you agree that local planning authorities should set out in plans how they will monitor and report on planning agreements to help ensure that communities can easily understand what infrastructure and affordable housing has been secured and delivered through developer contributions?

Answer: Yes

Question 17(b): what factors should we take into account in preparing guidance on a standard approach to monitoring and reporting planning obligations?

Comments:

It should be for Government to set out a standard data schema in say xml format to be used by all LPAs. This should be machine readable, and be possible to be aggregated and compared across LPAs.

Question 17(c): how can local planning authorities and applicants work together to better publicise infrastructure and affordable housing secured through new development once development has commenced, or at other stages of the process?

Comments:

A public, standard database as described above should be sufficient, together with normal reporting through Council press releases and magazines.

Question 18(a): do you agree that a further 20 per cent fee increase should be applied to those local planning authorities who are delivering the homes their communities need? What should be the criteria to measure this?

Answer: No

Comments:

It seems odd to give extra funding to those LPAs that are performing best, and no extra money to those who aren’t performing. You should let LPAs choose their own fee levels, subject only to the safeguard that they collect no more in fees overall than the costs of the planning department. These levels should not be set by national Government.

Question 18(b): do you think there are more appropriate circumstances when a local planning authority should be able to charge the further 20 per cent? If so, do you have views on how these circumstances could work in practice?

Answer: Not Sure

Comments: See 18a

Question 18(c): should any additional fee increase be applied nationally once all local planning authorities meet the required criteria, or only to individual authorities who meet them?

Answer: Not sure

Comments: See 18a

Question 18(d): are there any other issues we should consider in developing a framework for this additional fee increase?

Comments: See 18a

Question 19: having regard to the measures we have already identified in the housing White Paper, are there any other actions that could increase build out rates?

Answer: Yes

Comments:

A time limit should be set on completion of any site given planning permission. Any units not completed by the end date, should be subject to council tax (perhaps a punitive rate of council tax) to act as an incentive for developers to actually build the homes that have been awarded planning permission.

If say, 12 months after the end date, the homes have still not been completed, then the LPA should have the authority to compulsorily purchase the remains of the site at a knock-down price to be sold on to another developer to complete.

Hart Infrastructure Funding Gap as wide as ever

Posted on October 22, 2017October 22, 2017

Hart infrastructure funding gap £72m

New figures have been published by Hampshire that shows the Hart Infrastructure funding gap to be as wide as ever. The overall funding gap for Hampshire is £1.2bn and Hart’s share is £72m.

Hampshire infrastructure spending shortfall £1.2bn

Hart’s share of the gap is made up of:

Transport, £34m
Education: £38m.
Countryside: To be Determined.
Extra Care places: To be Determined.

No estimate has been made of the requirements or costs of additional healthcare provision.

Hart Infrastructure Funding Gap Transport

Hart District Strategic Infrastructure Schemes – Transport

The transport gap is £34m.

Hart Infrastructure Funding Gap Education and Countryside

Hart District Strategic Infrastructure Schemes – Education and Countryside

Education is the widest gap at £38m. Interestingly, this doesn’t include the costs of a new secondary school. The developers of Murrell Green have promised land and a contribution to a 9-form entry secondary school. This would amount to a 1,350 place school. A 150 place expansion of Robert Mays is indicated to cost £7.6m. It is therefore realistic to expect a 9-form entry, 1,350 place school would cost around £68m. Developer contributions from a 1,800 unit settlement might be expected to be £16m or so. This is calculated by assuming 40% of the development will be affordable housing, which does not attract S106 funding. It is assumed the remaining 1,080 open market dwellings would deliver S106 contributions of £15,000 per unit.

It is therefore clear that all of the developer contributions would be consumed by the new school, before any road improvements were made. And the road funding deficit is already £34m.

Hart Infrastructure Funding Gap Extra Care

Hart District Strategic Infrastructure Schemes – Extra Care

Hampshire identify the need for 221 more extra care units, but don’t identify the cost or say where the money will come from.

What does this mean for the Local Plan?

Community Campaign Hart are promising an “Infrastructure led Local Plan”. It is now obvious that a new settlement will only make the infrastructure funding gap worse. They are sticking to the ridiculous 10,185 housing target. If they adopted the new Government housing target of 6.132, then the infrastructure funding gap would be reduced. There would be fewer houses, therefore less need for road improvements. Fewer people and so less need for a new school. Indeed the latest figures from Hampshire show there’s no need for a new secondary school.

It is time to call them out on their plans and start asking “Show Me the Money”.