Brownfield Sites in Hart District
We Heart Hart has been asked to present to Greywell Parish Council about the Hart Council’s Local Plan tomorrow, 26 May 2015. The presentation we will give is available for download below:
Cows in Winchfield
Robert Worsley has made the news recently by famously turning down an offer of £275m for his land in Sussex, saying:
‘What would I be doing to my neighbours and the other farmers round here? I could not be held responsible for putting the area under concrete.’
His principled stand to protect the legacy he leaves behind for future generations has won admiration across the country.
Andrew Renshaw, one of the landowners in Winchfield took a stand against development even before Robert Worsley, by expressing his strong opposition to a new town and he put up signs saying his part of Winchfield is not for sale.
Might it be possible to persuade the other landowners in Winchfield to think about the legacy they might be leaving for future generations and turn down the offers from the voracious developers? That might force a much stronger focus on brownfield development and a more common sense approach to Hart Council’s Local Plan.
Vacant Sun Park (Guillemont Park) block near J4A of M3, Cove, Hart District, Hampshire
A preliminary application has been made to build 350 dwellings at the old Sun Park (Guillemont Park) site, near J4A of the M3, Fleet, in addition to the earlier application for a further 120 homes on another part of the site. Provided concerns over road access can be overcome, this looks like a valuable addition to our brownfield capacity.
On the face of it, this is good news but further illustrates how misleading Hart District Council’s figures about brownfield capacity were when the council voted for plans to test a new town at Winchfield back in November 2014. Back then, they estimated overall brownfield capacity at only 700 units.
However, even though this site (SHL152) was in their assessment of Land Availability (SHLAA), it underestimated capacity (300 dwellings compared to the total now at 470), and wasn’t counted as a brownfield site as it was included in their “Adjacent to settlement boundaries” section.
If Hart Council are serious about a “brownfield first” strategy, surely they must now create a proper register of potential sites and properly assess the capacity and feasibility of delivering our residual requirement on brownfield only sites.
If you are worried about Hart’s hopeless position on the Local Plan and like our 5-point plan to bring it back on track and add to the pressure to Hart to adopt a brownfield strategy and drop all ideas of a new town, the please sign and share our petition:
Vacant, derelict block in Hook, Hampshire
In a worrying development at the Hart Council meeting on Thursday 30th April, the leader of the council, Stephen Parker, ruled out creating a register of brownfield sites in the district, whilst at the same time insisting that the council supported a “brownfield first” strategy.
He said that the Strategic Housing Land Availability Assessment (SHLAA) had identified only 750 dwellings as being “deliverable” within the time-scale of the Local Plan.
The council insisted that all sites in the Local Plan must be “deliverable”. However, this is misleading as the term “deliverable” has a special meaning in planning terms and only applies to the first five years of the plan when it is submitted. Beyond five years sites only have to be “developable”.
We have previously posted that there are loads of mistakes in the SHLAA that have the effect of reducing the apparent brownfield capacity and the density assumptions that Hart uses are far below what they themselves say would be achievable in urban areas.
If Hart were to include “developable” sites such as the vacant and derelict offices, Bramshill House, Pyestock (aka Hartland Park) and Sun Park as potential sites and increase the density assumptions then it is entirely possible that the whole of our remaining housing requirement could be met by brownfield development.
Surely any credible “brownfield first” strategy should include as its starting point a register of all the redundant brownfield sites in the district.
If you would like to join the campaign to get Hart to think again, then please sign and share our petition:
NPPF Definition of Deliverable:
“to be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable”
NPPF Definition of Developable:
“to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged”
Vacant Block at Ancells Farm, Fleet, Hart District, Hampshire
Rushmoor Borough Council has produced a draft Employment Land Review (ELR) on behalf of Hart District Council, Surrey Heath and Rushmoor. We Heart Hart has examined this draft document and found some serious errors in the way they have calculated both the historic jobs growth numbers and the future jobs projections for the area. Moreover, after discounting the Experian methodology for calculating future jobs growth saying:
“Experian-derived forecasts which are considered unreliably high in that they make too many assumptions around unconstrained economic growth”,
they recommend that the scenario that is used for testing should be based on the numbers for housing development contained in the SHMA, which themselves are inflated by the self same Experian forecasts they earlier dismissed as unreliable. This is clearly an absurd position that results in the forward B-class job projections (598 per annum) being nearly double the rate (300 per annum) that would be achieved if we continued at the rate of growth that was delivered between 1998 and 2012. The impact of this is that the amount of employment land we need is being over-stated and so reducing the amount of brownfield land that might be available for housing. This represents a great opportunity for Hart Council to challenge Rushmoor to re-visit the ELR and revise it so that more brownfield land comes available across the three districts.
We have asked several questions about the errors we found, but have not received satisfactory responses. We urge you to contact your councillors and ask them to challenge Rushmoor to come up with more realistic estimates and revise the ELR before it becomes final and sign our petition:
The detail of the analysis is shown below.
ELR Table 8.2
The starting point for the analysis is Table 8.2 that shows the forecast employment change in a number of different types of jobs, from which it is possible to derive the ratio of B-Class jobs to all jobs at 53% (17,428/32,906). B-Class jobs means those jobs that require office space or light industrial units, rather than an indication that they are somehow inferior. Then we must look at Figure 7.12 that allegedly compares the historic rate of growth of B-Class jobs to the forward projections.
Figure 7.12 ELR
By inspection, Figure 7.12 shows the trend in B-Class jobs as approx 555 per annum from 2002-2012. The data from Table 8.2 allows us to derive total job growth of around 1,048 per annum. However, as we shall show below, this number is far in excess of the actual job growth achieved according to the SHMA.
The SHMA contains data on the historic rates of job growth. This shows two sets of data that are derived from different sources and cover different time periods (Figures 4.3 & 4.4 of the SHMA).
First, there is the period 1998-2008, covered by ABI data. This shows overall job growth in the period of 7,200, or 720 per annum for the 10 year period with a compound annual growth rate (CAGR) of 0.6%. This would equate to a growth rate of B-Class jobs of 382 per annum, far lower than the 555 jobs per annum shown in figure 7.12.
Second there are different BRES sourced data for the periods of 2009-2012. The BRES data from 2009-2012 shows total jobs growth of 200, or 67 per annum (35 B-Class per annum) for the 3 years in question or a CAGR of 0.05%, again far lower than the 555 in figure 7.12. It is difficult to see how the 555 number was derived since it is much higher than either period covered in the SHMA. Despite repeated questions, no one has been able to explain how they derived their number for Figure 7.12.
Comparison of the BRES data and the ABI data shows a discontinuity between 2008 and 2009, with a jobs increase of nearly 10,000 when we know the economy was in the teeth of a deep recession. Note that the report states that the ABI and BRES data cannot be directly compared because they are compiled using different methods. It is therefore clear that each period (and dataset) should be treated separately and independently rather than splicing them together.
Treating the datasets separately would indicate total jobs growth over the economic cycle of 7,400, or 529 per annum or a CAGR of 0.41%, based on backward extrapolation of the BRES data. This would equate to B-Class jobs growth rate of 280 per annum, or about half the number in Figure 7.12 of the ELR.
Taking the 0.41% rate of growth as a future projection would mean we would add 11,332 overall jobs over the period of 2012-2032 at an average rate of 567 total jobs per annum, or 300 B-Class jobs per annum.
However, the scenario recommended for testing in the ELR assumes a rate of B-Class jobs growth of 598 per annum (or total jobs growth of 1,128 per annum), nearly double the rate that would represent a forward projection of past performance over the economic cycle. Incidentally, this is almost the same number as the future jobs growth number contained in the SHMA, which is based on the same Experian forecasts that the ELR itself discredits.
Protect our green fields
In a sign that much of the South East of England is starting to revolt against the Government’s plans to concrete over our green fields, the Sunday Times has published an important article attacking “meaningless” garden villages and urban sprawl. This echoes the recent survey of Hampshire residents that put protecting our towns and villages as a key election issue. Just to be clear, We Heart Hart does not support the Rudlin proposal outlined in the article below of taking bites out of our green belt. We believe that Hart District’s housing need can be met from brownfield development.
It remains to be seen if our Parliamentary and District Council candidates will take heed. If you want to join 1,600 other people who want to oppose Hart District Council’s plans for a new town in Hart, please sign and share our petition.
The article can be found here and is reproduced below.
Beware the ‘garden village’: it’s not green and it’s not a village
by Charles Clover, Sunday Times
OUR nearby town has just leapt towards us. It vaulted the trunk road, previously a barrier to development, with a huge park-and-ride for 1,000 cars. The lights of that were turned on this month, just after a proposal for a new “garden village” of 4,000 homes emerged from the imagination of local speculators. Were this approved, it would push far north into green countryside and towards Constable country.
Our nearby town is Colchester but it might be anywhere in the southeast. The quandary is the same: how to provide enough land to build about 1,000 homes a year for the next 15 years to address the desperate need to house the young and to tackle rising house prices.
The town is under pressure to find the right number of homes to put in its local plan or it will lose control and be forced to approve every speculative proposal, as has happened in another local town, Braintree, when an inspector found its numbers too low. So a rather chilling thing has happened. Colchester issued a “call for sites”. This flushed out not only every farmer with a few acres he wouldn’t mind selling — the little red patches on the map of offered land in every village are a tale of rampant opportunism. The call has also galvanised some large landowners to band together and propose “garden villages” in green countryside.
Some are considered wildly speculative. But the largest of these proposals, up to 15,000 homes on the A12/A120 corridor known as West Tey, is being taken seriously. The landowners in question could then fly off to the Channel Islands with £1m an acre, leaving the rest of us to fund the roads, hospitals, railways and schools these homes will need.
This “landowner-led” process is a consequence of the government’s simplification of the planning system. It has taken out the layer of bureaucracy known as regional planning and pushed responsibility down to the boroughs. In a few years the effect of this may reduce the upward pressure on house prices. But it has left local authorities struggling to find sufficient land. Our own has done a good job, until now, of building on brownfield sites. Now the numbers are too great. It must consider green fields because it has no more brown ones. There are plenty of brownfield sites to the south, along the Thames, but there is no mechanism for pushing the development there because under the new system each borough must provide for its own population.
Sensibly, our borough has decided not to make every chancer’s day. It favours the idea of a few new settlements, still euphemistically described as “garden villages”. The thing is that 15,000 homes is not a village. It is a town. Without inspired planning, it is Los Angeles-style sprawl. Any resemblance to century-old garden cities, such as Letchworth, is purely coincidental. Developments such as West Tey are speculative and there is, as yet, no certain way of tapping into the windfall profits, known as “uplift”, to upgrade stretched infrastructure: our hospital has been under emergency measures, the roads are clogged and you may have to stand on the train to London.
The problem with the process here is that it has brought forward land along a main road that is already outdated, in green countryside that is not close enough to the local town for walking or cycling and on grade 2 agricultural land that is meant to be protected. Contrast what is going on in Ebbsfleet, Kent, where the same number of homes are planned: the government is pouring £200m into infrastructure and the settlement sits on the underused Channel Tunnel rail line. The windfall profits will be diverted into an urban development corporation — like the ones used to develop postwar new towns such as Harlow. This option does at least mean the public get the kind of town they need.
Thoughtful locals are pressing Colchester to think again about a town extension instead of meaningless “garden villages”. That debate is opening up across the country. The advocates of expanding existing towns cite the arguments made by David Rudlin, an urban planner who won last year’s £250,000 Wolfson economics prize: that postwar new towns lacked sufficient scale to be successful and stagnated economically when large employers closed. Rudlin favours instead taking “confident and well-planned” bites out of the green belt and developing them like new towns.
It is not too late for those arguments to prevail here — indeed, one of the options being considered in Colchester is an extension of 5,000 homes near the university. But it will take a jolt from local MPs after the election to get sensible options fully considered. That is nothing to the jolt there will be in the form of opposition, across the country, if wildly speculative developments like those I’ve seen find their way into local plans.
Protect our green fields
We know that progress on the Local Plan for Hart District is slow and that it is not going in the direction many would like to see. We thought it was time to outline an alternative approach, and see if Hart Council and the candidates for election will change their minds. Below we set out a five point plan for change:
1. Create a Medium Growth Scenario
We need to work on creating a reasonable, alternative “medium growth” scenario to go alongside the current “high growth” scenario. We have posted earlier about why we believe the SHMA is flawed (as shown here and here) and is forcing us to build too much – 7,534 houses in Hart plus 3,100 extra from Surrey Heath and Rushmoor. Hart District Council should work with Rushmoor and Surrey Heath work to create a joint new, “policy on” lower housing requirement for the whole Housing Market Area that:
The more realistic assumptions above could reduce the overall housing “need” for the combination of Hart, Rushmoor and Surrey Heath by around 8,000 dwellings from 23,600 to 15,790. We believe this would relieve the pressure on all three districts, and in particular, reduce the pressure on Hart to take the unmet needs of Surrey Heath and Rushmoor Boroughs.
2. Create a formal brownfield option and invite a competition to design the art of the possible
We have already demonstrated that Hart has no effective brownfield strategy. Hart Council should create a new, formal “reasonable suitable alternative” option of meeting the housing need solely through brownfield development. This should involve the following:
This could be done in conjunction with the neighbouring authorities of Surrey Heath and Rushmoor.
3. Do the work and consult upon the additional elements of a proper Local Plan
Hart District Council needs to work on the other elements that should make up a local plan such as education, retail, transport, employment, meeting the needs of the ageing population and other infrastructure. Hart should conduct suitable, high level strategic analysis to build an evidence base to answer the following questions:
For each option and scenario Hart should outline the total cost of infrastructure spending required and the likely contribution from developers so that a proper financial model can be created.
4. Consider the Environment and Landscape
Fourth, Hart should conduct the other studies that are required to update the evidence base such as the landscape character assessment and an assessment of the potential damage caused to our wildlife by over-development.
Once this work has been completed, Hart District Council should carry out a new Regulation 18 consultation on the above that includes both a medium and high growth scenario and the properly evaluated options for meeting the housing need including the new proposed “brownfield” option. It would be preferable if the current “Option 4 – New town at Winchfield” (or indeed a new settlement anywhere in Hart) was dropped as an option. It will be important for the council to step up its engagement efforts during this period to ensure that a much larger proportion of the public responds to the consultation.
After the results of the consultation is known, firm up a preferred growth scenario and delivery option(s) to work up into a more detailed Local Plan and conduct an exercise to ensure democratic endorsement of the preferred option. This could take the form of a district wide referendum or a series of Parish Polls, followed by a Regulation 19 consultation before submission to the inspector.
5. Fix the management and governance problems
Finally, Hart need to work on the setting up the Local Plan project properly and address the governance deficiencies. There is clearly no properly defined scope or deliverables as the recent questions to the Planning Inspector demonstrate. Moreover, the timeline keeps slipping as we were originally supposed to have been consulted on a draft plan in March 2015, and it is clear that Hart is nowhere near that milestone even though it has dropped that consultation from its plan. This indicates the Local Plan project is not properly resourced. The Council needs to appoint a suitably qualified, experienced project manager, follow a properly recognised project management methodology such as Prince 2 and invest in the proper resources required to carry out the project on time to proper quality standards.
Given the prior failure of the earlier Local Plan at inspection and the current hopeless path the new Plan is taking, it is also clear that the governance of the Local Plan is deficient, with power effectively concentrated into the hands of only two people. The Council needs to explore ways of separating powers so that there is better transparency and accountability on both the “officer” and “member” sides. We suggest that the project should report to the joint chief executive who is not also in charge of planning; that roles of council leader and portfolio head for planning are carried out by two separate people and the council members elect a more proactive and capable chairman. This should lead to a wider range of opinions to be heard and appropriate checks and balances to be implemented.
It remains to be seen if our Parliamentary candidates or our Hart District Council candidates will endorse this plan.
If you would like to join the campaign to change Hart’s mind, please sign and share our petition.
Countryside: minister says decisions should recognise intrinsic character and beauty
In a letter to Simon Ridley of the Planning Inspectorate, planning minister Brandon Lewis has drawn attention to the intrinsic character and beauty of the countryside. Will Hart Council heed this message when preparing the Local Plan?
A quote from the letter is shown below:
Landscape character and prematurity in planning decisions
I have become aware of several recent appeal cases in which harm to landscape character has been an important consideration in the appeal being dismissed.
These cases are a reminder of one of the twelve core principles at paragraph 17 of the National Planning Policy Framework – that plans and decisions should take into account the different roles and character of different areas, and recognise the intrinsic character and beauty of the countryside – to ensure that development is suitable for the local context.
The full letter can be found here.
This is an important development, and so far it looks like Hart District Council is ignoring this advice as it continues to test a new town at Winchfield, whilst ignoring the potential of brownfield development. Government guidance suggests that it inappropriate to use old documents, but the only one can find for Hart is dated 1997. We understand Hart District is going to commission a new study, but don’t yet know the terms of reference.
If you would like to add to pressure to Hart to change tack, remove Option 4 and focus on brownfield instead, then please sign and share our petition:
Election demands from Hampshire residents according to Get Hampshire
A survey of Hampshire residents by Get Hampshire has shown the protection of our green and pleasant land and historic towns and villages is a key election issue. This issue ranked third behind controlling immigration and helping our small businesses.
Looking at the questions and answers in more detail, a staggering 77.7% of people thought either that our green and pleasant land was of paramount importance or there were other legitimate sites available for development that councils should look at rather than using green space.
Get Hampshire Housing Crisis Questions and Answers
This shows an overwhelming majority in favour of protecting our historic towns and villages and protecting our green fields from over-development.
How to tackle the housing crisis from Get Hampshire
Only 12.3% of people wanted us to build thousands of houses in new towns and garden cities, whilst 36.4% of people wanted tax breaks to encourage building on brownfield sites.
Surely it is time for Hart District Council to think again about a new town at Winchfield, reject Option 4 and focus instead on creative use of the many brownfield sites in the district. Time also for Ranil Jayawardena and Gerald Howarth to take a message back to Conservative Central Office (and Parliament if they are elected) about changing the National Planning Policy Framework to reduce the pressure on local councils.
Focusing on brownfield and regeneration of our town centres will make better use of that land and build more critical mass to support the local retailers so would help with meeting two of the top 3 election issues.
If you would like to join our campaign to ask Hart Council to think again, please sign and share our petition:
As an addendum, protection of greenbelt by building on brownfield sites is a key issue for Surrey residents too.
Surrey Election Demands from Get Surrey
Derelict Offices in Fleet, Hampshire
In a piece of good news on Thursday night, Hart District Council conceded that it would be possible to build at higher density than they previously planned on brownfield sites in the district. The detailed questions and answers can be found here.
Hart District Council uses a rule of thumb of 30 dwellings per hectare (dph) for most sites in its database. We Heart Hart put to them that it might be possible to plan for up to 250dph in urban areas and still create vibrant communities. Hart rejected such high densities, but did concede that densities of 80-160dph might be possible.
Hart District Council answer to brownfield question
This is a very significant move. Currently Hart District Council have said the capacity of brownfield is around 700 dwellings, based on 30dph. However, if the capacity was scaled up to an average of say 120dph, the capacity increases to 2,800 dwellings. Moreover, there are a number of brownfield sites such as at Ancell’s Farm in Fleet and Bartley Wood in Hook that are not in the Strategic Housing Land Availability Assessment (SHLAA), and so there is even more capacity available.
This could take us within spitting distance of meeting the remaining 4,000 houses that have yet to be granted planning permission for the Local Plan, without concreting over our green fields. This would mean we would not need a new town in Winchfield nor do we need more strategic urban extensions in Fleet, Church Crookham or Hook. A further advantage would be that the centre of Fleet could be rejuvenated and could sustain more shops and amenities.
This is clearly good news, but it remains to be seen whether Hart District Council will take this opportunity seriously as there answer to the supplementary questions were not particularly encouraging.