Hart Tories claim victory despite abject failure

Hart Tories (NE Hampshire Conservatives) claim victory despite abject failure

Hart Tories (NE Hampshire Conservatives) claim victory form abject failure

North East Hampshire Conservatives have managed to claim victory, despite their abject failure to plan for a sensible amount of housing for Hart District.

On Thursday, the Conservative led Hart Cabinet agreed to plan for more than 10,000 houses. This is many more than is required to meet the needs of Hart residents. Yet, because they have managed to avoid putting those houses near Fleet, they claim it as some sort of victory. They show no concern for Hart residents who live in the more rural areas.

Apparently, the Hart Tories are concerned about over-development, transport, traffic, education, loss of green space and the impact of development on existing infrastructure. But only in the immediate area around Fleet. The rest of us will just have to suffer.

To recap, to meet the demographic projections for Hart residents and meet the needs of those who can’t get on the housing ladder, we need to build 6,000-6,500 new dwellings. Anything over and above that requires massive in-migration to Hart. That is, massive in-migration of people whose housing needs are supposed to be met elsewhere. The SHMA also assumes that most of these people will work outside the district, putting even further pressure on local infrastructure.

Hart is planning for more than twice the demographic projections. They are not alone, other nearby districts are planning for 42% more houses than the demographic projections require.

However, their so-called victory may be short lived. The Grove Farm application is being appealed by the developers. The Planning Committee also has to make a decision about Pale Lane soon. It seems likely that they will turn it down. However, it seems equally likely the developer will appeal that decision too. With no Local Plan, out of date policies and a questionable 5-year land supply, the inspector may well grant permission for both these sites.

The only sensible way out of this, is to remove the extra 2,000 houses they voted through on Thursday and demonstrate that the houses are not required.

Hart Cabinet sell us down the river as they plan for 10,000 houses

Hart Cabinet sell us down the river by planning for far more houses than we need

Hart Cabinet plan for houses we don’t need

Hart Cabinet sold us down the river on Thursday night as they voted to plan for 10,000 houses to be built in Hart District in the period up to 2032.

Aside from vote on the paper some other interesting information was disclosed on a number of subjects:

  • Hart Cabinet vote on the 10,000 houses?
  • Do we need a secondary school?
  • Grove Farm (Netherhouse Copse) update
  • Hart Cabinet and Council politics

Hart Cabinet vote on the 10,000 houses?

Well, the short answer is we don’t. Our statement was received without challenge and was described as “informed” by the joint Chief Executive. There really is no answer to the points about double counting, nor the extra 1,200 houses on top of the alleged additional affordable housing requirement. To his credit, Ken Crookes asked some challenging questions. He didn’t really receive satisfactory answers.

The cabinet chose to plan for the extra 2,000 houses on top of those set out in the Strategic Housing Market Assessment (SHMA), even though Ken abstained.

The plan was supported by two cabinet members from Hook. They apparently favour a new settlement that will deliver more houses in Hook Parish. But they vehemently oppose the proposed new development to the west of Hook, that is outside the Thames Valley Heath SPA zone of influence.

There is a risk that Hart will no longer have a five year land supply, now it has agreed an uplift to 10,000 houses. Apparently, officers are working on a new document.

The leader and joint chief executive will now proceed to produce a draft Local Plan. A new consultation will be held on this draft will begin some time in March.

Do we need a new secondary school?

One of the justifications for the new settlement at Murrell Green is that the district needs a new secondary school. You may recall that the council voted on a resolution to include a secondary school in the Local Plan.

However, in his statement to cabinet, the joint chief executive said that although:

Hampshire County Council (HCC) welcome the principle of a new school site, the scale of growth envisaged in the Local Plan is not one that would require the delivery a new school in the planning period.

HCC is responsible for planning school places. But HCC is not responsible for delivering new schools as they will now be delivered as free schools, outside local authority control.

Apparently, Hart has also been offered secondary schools by the developers of Winchfield, West of Hook and Rye Common.

In other words, Hart has acted outside its responsibilities in resolving to deliver a site for a school and the authority responsible for planning school places don’t believe we need a new school. So, we are creating a new settlement to create capacity for houses we don’t need and a school we don’t need either.

Grove Farm (Netherhouse Copse) update

In conversation we found out more about the Grove Farm application. The developer has now appealed this case on the grounds of non-determination.

Community Campaign Hart (CCH) screwing up Hart Planning since 2004

To re-cap, the Community Campaign Hart (CCH) chair the planning committee and failed to make a decision on the application at last December’s planning meeting. The council officers has recommended approval.

Hart is going to fight the appeal, probably on the grounds of wishing to maintain the Local Gap between Fleet and Crookham Village.

If Hart does lose its five year land supply, then this will make things difficult at appeal.

Apparently, the risk of losing £1.6m of New Homes Bonus has been mitigated because the indications from Government are that they are no longer going to push through those proposals.

However, there is still a significant risk that Hart will lose this appeal. The expectation is the appeal inquiry will be held in June, with a decision in August.

Hart Cabinet and Council Politics

We have now heard from several sources that one of the reasons Hart Cabinet appears to be so dysfunctional is that the ruling Conservative Party fears a vote of no confidence over the summer. This would entail CCH bidding to oust the Tories, presumably to be replaced by some sort of CCH/Lib Dem coalition. Maybe, the CCH coup is dependent upon the outcome of the Grove Farm appeal.

So, it appears as though we are planning for the extra houses to deliver a new settlement and secondary school we don’t need to appease CCH, who would prefer the new settlement at Winchfield.

It does seem very odd that we are having a new settlement forced upon us by dysfunctional politics.

 

 

Statement to Hart Cabinet

Hart District Council and Hart Cabinet Offices, We Heart Hart. We Love Hart

Statement to Hart Cabinet

The crucial Hart Cabinet meeting to decide the spatial strategy to be incorporated in the forthcoming consultation on the Hart Local Plan will be held tonight at 8pm.

Public participation is allowed and we have been allowed to speak. A copy of our prepared statement is shown below. Please do come along and watch the debate.

Statement to Hart Cabinet 9 February 2017

Thank you for allowing me to speak.

This is an important time for Hart – you are setting out a strategy that will impact the quality of life of Hart residents for many years to come, so it is important you do the best job you can.

Hart Council is in a perilous position and facing the threat of losing around £2m of NHB if the Local Plan is not in place on time and of course the threat of many speculative planning applications. So, it is right that you are risk averse at this time.

However, I would like to use this statement to persuade you to change direction.

I would like you to focus on reducing the housing target of 10,000 by removing the unnecessary uplift of 2,000 extra houses on top of the SHMA target of ~8,000.

The SHMA starts with the ONS population and household projections. It says the “the household projections… are statistically robust and are based on nationally consistent assumptions”. They take account of international migration and migration between districts.

On their own, these projections would point to a need for around 5,300 houses over the planning period. If, however, the SHMA used the more up to date 2014-based figures, the housing need would fall to around 4,500, compared to the 10,000 you are proposing to build.

That’s right, the latest demographic projections point to a need that is less than half of that you are proposing.

However, it is probably right that the housing target should be inflated a little to cater for what is termed suppressed household formation and concealed households.

The SHMA has done this by firstly increasing Hart’s target up to around 6,100 new dwellings to cater for households that are termed ‘can’t rent, can’t buy’ and those who can rent but can’t buy.

Secondly, it then makes a further increase of around 500 affordable homes. This brings the total target to around 6,600.

To my mind 6-6,500 houses would be reasonable overall that would mean we could meet the rest of the target from brownfield sites alone.

To emphasise: The SHMA has met the demographic need and already takes account of suppressed household formation, concealed households and affordable housing.

The SHMA then goes on to add a further 1,400 houses for economic growth, bringing the overall total to 8,000.

This ‘economic growth uplift’ does by definition mean that you are planning for additional inward migration to Hart, people whose needs are supposed to be met elsewhere. Not only that, the SHMA assumes many of these people will also work outside the district and thus put increasing pressure on the creaking transport infrastructure. This is not sustainable development.

Yet, you are now proposing to add a further 2,000 houses to the total to meet extra questionable affordable housing needs.

However, we have already established the SHMA itself has already taken account of the affordable requirement, so this extra 2,000 is double counting.  It will require us concreting over our green fields to meet non-existent housing needs. This is unsustainable over-development.

We wouldn’t need the new Murrell Green settlement if you removed the 2,000 unnecessary houses from the target. I might add the new settlement is entirely unsuitable. It is bordered by the M3 and A30. Criss-crossed by the railway, power lines and a high-pressure gas main. A big chunk of the site is former landfill. Only last year a solar farm was turned down on the grounds it would spoil the view from the Odiham Deer Park and spoil the enjoyment of walkers on the public footpaths. This proposal is far more intrusive than solar panels.

So finally, I urge you, please do the right thing and plan for a sensible housing target. Don’t blight our green fields with so many unnecessary houses. If you really want to help the concealed households, make sure you allocate some of the existing housing target to subsidised social-rented accommodation.

How should we deal with the ‘housing crisis’?

Housing Crisis

There is much hand-wringing in the media today about the so-called ‘housing crisis’. We have done quite a bit of research on this topic and come across three important articles by Ian Mulheirn of Oxford Economics. His articles show we have a crisis of low interest rates, not a crisis of too few houses. We summarise his arguments here and provide links to the full articles below.

Is there really a housing crisis?

The conventional wisdom is that there is a serious housing crisis, as per the FT:

  • We don’t have enough housing. The UK has an ‘endemic shortage of housing’ as housebuilding has ‘lagged behind population growth’.
  • Housing costs are high as a result. These have ‘wiped out income gains made by the bottom half of households’ over the past 13 years.
  • Building more will solve the problem, especially for the less well-off. ‘The fundamental problem is one of supply’ it argues, and boosting it will substantially benefit those people who are ‘just about managing’.

But, if you are to solve a problem, you need to unpack it and home in on the real issues.  Some argue there are too few houses for people to live in, then the evidence simply doesn’t back it up. Since 1990 there were 3.0% more houses than. Latest ONS estimates show that has risen to 5.2%. Since 1971 surplus dwelling stock has risen from ~0.2m to around 1.4m.

Housing Crisis? There's Surplus Housing Stock

Surplus Dwelling Stock: Source: DCLG tables 401 and 101; ONS households from 2011

The reason for the panic is that the DCLG systematically over-estimate the number of households there are going to be:

Inaccurate DCLG forecasts of household growth

And some official numbers underestimate the number of new dwellings by only counting newly built stock and ignoring things like conversions:

Housing crisis? Inaccurate measurement of new housing stock

This might explain why developers are not building as fast as they are being granted planning permission. If they built faster, then there wouldn’t be demand for their output.

So, if the housing crisis is not about a shortage of places for people to live, what has happened to the cost of housing?

Are housing costs too high?

Might the housing crisis be caused by the costs of housing? Well, strange as it may seem, like for like rental costs are pretty stable in real terms:

Like for like costs of rent

Like for like costs of rent: Source ONS

And the costs of owning are falling, compared to renting. That is if you measure the real cost of owning, which is interest costs of a mortgage plus maintenance and taxes. This doesn’t cover the repayment element of a mortgage, which is really just another savings vehicle.

Costs of rent versus owning

So what is causing the housing crisis? There’s no shortage of housing and housing costs are not high.

Why are house prices so high and will building more bring them down?

The short answer is house prices are so high is because interest rates are so low.

What it undeniably faces, however, is very high house prices. UK house prices are now over 150% higher in real terms than they were 20 years ago. How can such an escalation of prices have occurred if there isn’t a shortage of places to live? The answer lies in the fact that housing has a dual function: it’s a place to live but it’s also an asset that pays a return in the form of the owner occupier not having to pay rent….

This means that as global interest rates fall, house prices will inevitably rise. Indeed if the real cost of ownership were to halve, we’d expect prices to double, which, as it happens, is broadly where we are vis a vis 20 years ago.

So putting it all together we have:

  • no firm indication that there are too few dwellings for the number of households in the UK relative to 20 years ago;
  • evidence that the cost of housing in either tenure has fallen over the past decade, and is broadly comparable with 20 years ago in real terms;
  • a steady fall in mortgage, and more generally global, interest rates that we would expect to lead to a substantial price response regardless of the adequacy of the housing stock.

So, what do we do about it?

Well, there’s no easy answers, but granting permission to build more on our green fields, or even building many more houses won’t make much difference to house prices. Indeed, building too many more houses might result in big issues like they had in Spain and Ireland:

But building many more houses than people want to live in is a dangerous route to go down, as Spain and Ireland can attest. For comparison, Ireland had an estimated surplus of dwellings over households of around 14 percent on the eve of the financial crisis (which among other things proves that households don’t just form because there are vacant houses). This building mania was something like the equivalent, relative to stock, of the UK adding 1 million new dwellings per year from 2002–11. But even this didn’t do anything noticeable to rein in Ireland’s property market during the boom, with prices rising by a fair amount more than the UK’s. A similar story can be told in Spain.

Conclusion

In our view, if we want more places for young people to afford to live in, we have to build more social rented accommodation. Certainly, doubling Hart’s housing target from the 5,000 or so required by natural population change, to over 10,000 is not the answer.

Ian Mulheirn’s articles can be found on the links below:

Part 1: Is there *really* a housing shortage?

Part 2: Are housing costs high?

Part 3: Why are prices so high and will building more bring them down?

Hart Housing Target increased to 10,000

Hart Council goes through the looking glass as it ups the Hart housing target to 10,000

Through the looking glass as Hart housing target increases to over 10,000

We have gone through the looking glass as the Hart Housing target has been increased to over 10,000.

Hart has now published the document that will be discussed at Cabinet on Thursday 9 February. The main headlines are as follows:

  1. The Hart housing target has been increased to 10,077, with shall we say, questionable justification
  2. The proposed housing allocations are outlined, including a new settlement at Murrell Green

Hart housing target increased

The housing target has been increased to 10,077 as per the table below. This represents a 125% uplift on the 2014-based demographic projections.

ItemItem totalTotal
Housing demand as per 2016 SHMA8,022
Flexibility2,055
Affordable housing rental uplift520
Rural exception site delivery50
Starter homes/shared ownership285
Market housing1,200
Total "Need"10,077
Completions 2011-2016(1,830)
Commitments (to 31 Jan 2017)(3,385)
Windfalls(297)
Remaining to meet need4,565

This is a very questionable increase. The SHMA already factors in a 53% uplift on the ‘natural’ demographic projections, which would give a total requirement of 5,334 dwellings. But if they had used the more up to date 2014-based projections, the start point would fall to 4,473. If we were to use the raw 2014-based figures as our total housing target, we would have already built or permitted the total requirement.

Second, the justification to increase the total to 10,077 is to build 855 extra affordable/starter homes. But the overall increase is set at 2,055 because they don’t expect to build more than 40% affordable properties. This is simply absurd.

Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

Third, the SHMA has already made allowance for extra affordable homes (as can be seen above), and then this has already been uplifted for extra so-called jobs growth, which themselves will deliver more affordable homes.  Hart Council seems to be adding uplift on top of uplift in a quite random and arbitrary way. We have already analysed the SHMA here and here.

Fourth, the paper itself says there is no well proven evidence-based formula to uplift the housing target. There is nothing in National Planning Policy Framework (NPPF) that requires the target to be uplifted in a mechanistic way. Nor that the requirements have to be met in full.

No need to increase the Hart Housing Target to meet afordable homes requirement

Hart Affordable housing uplift

In short, the proposed uplift is double counting uplifts that have already been made that we are under no obligation to meet anyway.

If we were to build at this inflated rate, then this would be carried forward and compounded in future demograpgic projections.

Housing Allocations

The paper sets out the proposed allocations to meet this fictitious target, including 1,800 new houses at Murrell Green.

Housing allocations to meet the Hart Housing Target

Hart District housing allocations

No mention is made of Bramshill or Grove Farm (Netherhouse Copse), which are currently under consideration by the COuncil. Indeed we understand that the developers have appealed the Grove Farm application on the grounds of non-determination. Hart were already late in considering the application in December and cancelled the January meeting. Grove Farm is not on the agenda for the February meeting. It is difficult to see how they can defend the appeal.

Conclusions

Hart District Council is in a very perilous position. If it doesn’t get a Local Plan in place soon, it will lose around £2m per year in New Homes Bonus.

So everyone has a strong incentive to get a Local Plan. But by increasing the target to over 10,000 houses, everyone loses for decades to come.

It is difficult to work out the best way forwards. We could either wait until the Regulation 18 Consultation comes out in March and hope that we can influence matters for a better outcome. Alternatively, we can fight now for radical change of both the plan and the people running the process.

Is the Murrell Green new settlement viable?

Murrell Green new settlement proposal

Murrell Green new settlement proposal

We wrote yesterday that the council has prioritised the Murrell Green new settlement as part of the Hart Local Plan. However, there are very real questions about the viability of these proposals.

  • Environmental concerns
  • Infrastructure issues
  • Coalescence of Hartley Wintney and Hook
  • Financial stability of the promoter

Environmental concerns about the Murrell Green new settlement

Part of the site includes Beggars Corner which is the triangular piece of land between the railway and motorway. A proposal for a solar farm on this land was turned down at appeal last year. The main reasons for turning it down were:

  1. Harming the enjoyment of those walking the public footpath across the site. This is shown as a dotted red line on the map
  2. Spoiling the view from the Deer Park at Odiham

Houses are obviously taller than solar panels, and indeed some houses might have solar panels on their roofs. So, how can it be sensible to build houses when solar panels were deemed inappropriate?

Furthermore, a significant part of Beggars Corner used to be landfill, with unknown contents

SHL 167 Landfill details Beggars Corner

SHL 167 Landfill details Beggars Corner, Winchfield, Hart District, Hampshire

It is not appropriate to build houses on this type of land. Nor should it be promoted as green-space for children or dog walking when we don’t know what toxins lie beneath.

It should also be noted that a 110kV electricity transmission line traverses the site as well as a high pressure gas main. Hardly appropriate for housing or recreation.

Gas Main through Murrell Green new settlement Site

Gas Main through Murrell Green Site

The site is also within the Thames Valley SPA 5km zone of influence. There are three Sites of Interest to Nature Conservation (SINC) on the site plus a further SINC just to the west at the River Whitewater.

Finally, there are a number of public footpaths that currently criss-cross the site and they appear to be destoyed by this new proposal.

Infrastructure Issues

The only access to the south of the proposed Murrell Green new settlement is Totters Lane. This is single track in places with a very narrow bridge over the railway. To the north there is the A30 which is already very busy, with choke points at Phoenix Green, Hartley Wintney and the roundabout in Hook. It is difficult to see how these choke points can be alleviated.

Those of us who use Winchfield station know that the car-park is frequently full to capacity and of course, the whole line to London is running over capacity. The idea that either Hook or Winchfield stations can accommodate the extra passengers from thousands more houses is simply laughable.

In addition, the previous strategic assessment of Murrell Green included concerns about:

  1. Healthcare provision – I can speak from personal experience that Whitewater Health that covers Hook and Hartley Wintney is full
  2. Primary school provision
  3. Availability of supermarkets

Coalescence of Hartley Wintney and Hook

The proposed site abuts the south western boundary of Hartley Wintney parish and is close to what are currently quite widely spaced houses.

Hook SHLAA sites in Hart District, Hampshire

Hook SHLAA sites in Hart District, Hampshire

The western side of the Murrell Green new settlement comes within a couple of hundred metres of the new development to the NE of Hook (sites 1, 2 and 3 on the image above). Note that sites 4 and 126 on the map above are not (yet) included in the new settlement proposal.

In essence, we are creating Hartley Winchook.

Financial viability of the promoter

Last year, it came to light that there was a ‘secret plan‘ for a very large settlement that included both Winchfield and Murrell Green. The Murrell Green part of the proposal was promoted by a company called Pearson Strategic Limited.

There are a number of pertinent facts about this company:

  1. It only has one director, James Turner
  2. It was only incorporated in November 2014 and has no revenue
  3. At the time of its last accounts, it has a negative net worth of £3,240
  4. Its only real asset is promotion rights over Totters Farm that has been mortgaged under a fixed and floating charge to Monopro Limited.

One really has to question whether we should be building the Hart Local Plan around a site with such little backing.

Accounts to Pearson Strategic can be found here.

Fixed and Floating charge document can be found here.

Conclusion

Some Hart Councillors seem hellbent on a new settlement regardless of the suitability or viability. In addition, they have not challenged the new Strategic Housing Market Assessment (SHMA) hard enough. If we are sensible about the housing targets and get properly serious about the brownfield opportunities we don’t need a new settlement anywhere in Hart.

Time to make our voice heard again.

 

Breaking News: Hart proposes new settlement at Murrell Green

Murrell Green new settlement proposal

Proposed new settlement at Murrell Green

Hart District Council has proposed a new settlement at Murrell Green as part of its spatial strategy for the Hart Local Plan. This was debated at a meeting of the Local Plan Steering Group last night. The proposal is expected to be agreed at a special Cabinet Meeting to be held on 9 February at 8pm.

The new settlement contains a site for a proposed new secondary school, outlined in yellow in the image above.

We are delighted that the new settlement at Winchfield will not form part of Hart’s strategy.

However, we are disappointed at seeing Murrell Green being put forward as a solution.

[Update] Concerns have been raised about the viability of the proposal [/Update]

Brownfield Capacity

At the council meeting last week, the Leader admitted that Hart now estimate the brownfield capacity at 2,126 dwellings. This excludes the former police college at Bramshill.

HDC Question about brownfield capacity

A realistic assessment of the capacity of Bramshill is around 250 units, bringing the total up to 2,376. However, sadly, Moulsham Lane has been given the go ahead (150 units). This would mean we would have capacity to meet even the over-stated remaining requirement of the old Strategic Housing Market Assessment (SHMA) on brownfield sites alone.

New SHMA overstates the true housing requirement

However, it now appears as though the council has caved in to demands to build even more houses that we don’t need. They have agreed to an increase in our housing allocation to 8,022. On a like for like basis, this leaves us short by 462 units.

This shortfall might well be met by the Netherhouse Copse application (436), which we now understand has been appealed by the developers on the grounds of non-determination. So even with the new SHMA, there is no need for a new settlement at Murrell Green.

At council last week, the leader refused to answer our questions about the reasonableness of building houses to increase inward migration to the district, when many of those people would work outside the district and thus put pressure on infrastructure.

HDC Question about housing numbers

The assumptions I put forward are all in the new SHMA, see here.

We need to challenge this new SHMA and resultant spatial strategy strongly. This will ensure we build the right number and right type of houses to meet local needs, rather than needlessly concrete over our precious green fields.

The full minutes of the council meeting can be found here.

 

 

 

Hart Local Plan: Green fields or fictitious jobs?

 

Should Hart concrete over its green fields for the sake of uncertain jobs forecasts

It is now becoming clear that the forthcoming Hart Local Plan will present us with a choice of concreting our green fields versus building houses for people who live elsewhere and many of them will work outside the district.

We have now had the opportunity to read the new Strategic Housing Market Assessment (SHMA) in more detail, and in particular the detail of the main driver of the housing target uplift: the jobs forecast. We have found:

  1.  The jobs forecasts uplift SHMA calculations increase the overall housing requirement for the Housing Market Area (HMA) that includes Hart, Rushmoor and Surrey Heath by 22% over and above those required by demographics and making allowance for market signals
  2. The National Planning Policy Guidance (NPPG) does not require Hart Local Plan to accommodate extra housing if jobs forecasts are in excess of forecast workforce changes in the area.
  3. The SHMA calls the jobs forecasts ‘uncertain’ and ‘divergent’
  4. If we follow the SHMA, the Hart Local Plan will plan for jobs levels closer to the the extreme high end of the jobs forecasts
  5. That all of the alleged extra jobs will have to be filled by people coming from outside the district, and many of them will work outside the district. This will have a big impact on local infrastructure, particularly roads, rail, schools and healthcare facilities.
  6. Planning for around 900 extra jobs per annum would mean we could meet our remaining housing needs from only brownfield sites
  7. The SHMA says that it would be a more sustainable policy position to plan for increased economic growth to come from productivity improvements, rather than adding lots of lower skilled jobs

This is clearly a ridiculous position, and Hart District Council should follow the advice of Peter Village QC, and consult on the level of employment we wish the Hart Local Plan to accommodate and offer us the choice of planning 900 extra jobs per annum to protect our green fields.

[update]

We would suggest the following approach to the consultation:

Option A, plan for 900 jobs per annum, and around 6,500-7,000 houses, which can be achieved on brownfield (Hartland Village, Bramshill and Sun Park) or

Option B, plan for 1,200 jobs per annum and >8,000 houses for which you will have to give up Grove Farm, and some other area like Murrell Green and/or Pale Lane or West of Hook

We think there would be overwhelming support for Option A, and we would still be planning for 250 extra jobs per annum than the demographics would suggest, so meeting the requirement for positive development.

[/update]

We set out our analysis below.

What does the NPPG say we must do?

As can be seen below, the NPPG simply asks that plan makers ‘consider’ what they should do if the jobs forecasts are in excess of the forecasts for working age population. In particular, it asks for both housing and infrastructure to be considered.

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

How should employment trends be taken into account NPPG Para 018 Ref 2a-018-20140306

Indeed the SHMA itself says that the NPPG does not require plan makers to make any uplift in housing numbers at all.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.50 NPPG does not require housing uplift

SHMA 11.50 NPPG does not require housing uplift

So, whilst the impact on housing and infrastructure should be considered there is no requirement to to actually increase the housing numbers.

What do the jobs forecasts say?

There is a wide range of jobs forecasts ranging from 910 pa (Experian), through 950 pa (Cambridge Econometrics) to the extreme forecast of Oxford Economics at 1,480 per annum.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Section 5 summary range of forecasts

SHMA Section 5 summary range of forecasts

The SHMA acknowledges that the housing numbers required are extremely sensitive to the jobs growth assumptions made

SHMA 11.1 wide spectrum of forecasts

SHMA 11.1 wide spectrum of forecasts

The SHMA calls for us to plan for 1,200 extra jobs per annum which is closer to the extreme high end of the Oxford economics forecast.

What does the SHMA say about the Employment Forecasts?

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

SHMA 11.74 and 11.75 Genuine uncertainty no need to plan for extremes

The SHMA says that there is genuine uncertainty about the scale of jobs growth that might be expected and the forecasts are widely spread and divergent.

Where would the people come from and where would they work?

We are told that the extra people to fill these jobs would come from other areas:

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment SHMA 11.56 Population growth from inward migration from other areas

SHMA 11.56 Population growth from inward migration from other areas

If other local authorities are following NPPG, they should already be planning housing for these people. Indeed we have found that many planning authorities are planning for an average of 42% more housing than demographic trends would suggest they need.

But it gets worse, in that the SHMA would lead to many of these inward migrants working outside the district, putting unsustainable strains on the transport network. We already know the rail network is forecast to be running well over planned capacity with no real plan to fix it.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.51 Excess housing supply could lead to extra out commuting

SHMA 11.51 Excess housing supply could lead to extra out commuting

Currently, more than half of Hart’s working population work outside the district and 40% of the HMA’s working population work outside the HMA.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.1 and S11.15 out commuting calculation errors

SHMA Figure 11.1 and S11.15 out commuting calculation errors

What would the Hart Local plan be if we planned for fewer jobs

If we planned for closer to 900 extra jobs per annum, we would need 950 houses per annum in the HMA. Hart would need 305 per annum, leading to an overall housing requirement of 6,405 which would mean we wouldn’t need any more green field sites.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figures 11.13 and 11.14 housing projections for range of job growth

SHMA Figures 11.13 and 11.14 housing projections for range of job growth

Taking account of market signals, the housing requirement for the HMA would be around 1,050 per annum. This would lead to Hart’s overall need being around 7,000. Again, we wouldn’t need any more green field sites to meet this requirement.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

SHMA Figure 11.17 Housing projections taking into account market signals and jobs forecasts

What does the SHMA say about economic growth?

The SHMA says it would be more desirable to achieve economic growth through productivity enhancements and it would be a more sustainable solution.

Hart Surrey Heath and Rushmoor (HRSH) Strategic Housing Market Assessment. SHMA 11.55 Better to achieve economic growth through productivity improvement

SHMA 11.55 Better to achieve economic growth through productivity improvement

So, why don’t we go for a more sustainable solution and plan for 900 extra jobs per annum?

New Hart SHMA published: housing target rises despite falling population projections

The Scream - 2016 New Hart SHMA also covering Rushmoor and Surrey Heath

The 2016 new Hart SHMA also covering Rushmoor and Surrey Heath has been published and Hart’s housing target has been increased from 7,534 to 8,022. This increase comes despite the forecast population for 2032 being lower than assumed in the 2014 SHMA.

For those uninitiated in the terminology of the Local Plan, the SHMA is the Strategic Housing Market Assessment. This is the totally objective document that is entirely above any criticism because it is produced by consulting only those who have a vested interest in building more houses.

Just like the last SHMA, a number of spurious assumptions and arbitrary uplifts have been applied to artificially increase the housing target to 53% above what we would need if we stuck to the demographic projections.

Essentially, we are being asked to concrete over our green fields to build houses for people who need to move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. Other districts should already be planning to house those people.

Here is the summary of how they did it, followed by our critique of the methodology and results:

2016 new Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 12.2 Stages of Objectively Assessed Need Hart Rushmoor and Surrey Heath SHMA

Demographic Startpoint

They have used the 2012-based population projections to arrive at the 785 dwellings per annum for the whole housing market area (HMA), consisting of Hart, Surrey Heath and Rushmoor. This results in a housing need of 254 dwellings per annum or 5,334 for the whole planning period up to 2032. Already most of this target has been built or permitted in Hart. If we stuck to this, we would not need to grant permission on any of the sensitive green field sites like Grove Farm (Netherhouse Copse), Elvetham Chase (Pale Lane), Owens Farm (West of Hook), Murrell Green or Winchfield.

However, even this starting point is inflated. The new SHMA states that if they used the 2014-based population projections instead, then the starting point would fall by 94 dwellings per annum for the HMA as a whole. The target would fall by 41 dpa for Hart, or a total of 861 dwellings.

2016 New Hart SHMA Figure 6 Appendix H impact of 2014-based SNPP Hart Rushmoor and Surrey Heath SHMA

2016 New Hart SHMA Figure 6 – Appendix H: Impact of 2014-based SNPP projections

Market Signals Uplift

This starting point is then inflated for ‘market signals’ and affordable housing requirements. We agree that there is evidence that younger people cannot get on the housing ladder, or in some cases cannot even rent properties in the area because property prices are too high. The uplifts they recommend increase the target by ~15%, resulting in 903 dpa for the HMA and 292 dpa or a total of 6,132 for Hart. Again, the remaining target for Hart could easily be met from brownfield development at Pyestock (Hartland Village) and Sun Park.

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

2016 New Hart SHMA Figure 9.22 adjustments to demographic starting point

However, we do challenge the methodology they have applied in this case. They run two scenarios to estimate the extra houses required to meet the needs of people who are apparently not forming households at the expected rate. These would result in a 7-14% increase in the number of houses.

However, they arbitrarily choose a 15% uplift, which is larger than either of their modelled scenarios.

Even the SHMA itself calls into question whether this uplift will actually achieve anything:

9.72…Of course, there is no way of knowing in advance exactly how improvements in housing affordability would increase household formation rates (if at all)

Moreover, there is no evidence at all that simply allocating more land for development will either increase the number of houses being built or reduce the price of housing. The same section shows that development land in Hart, with planning permission costs £4.1m per hectare (section 9.12). At Hart’s preferred housing density of 30 dph, this equates to the land cost alone of a new home being around £133,000.  Build costs, S106 contributions and a profit for the developer could easily see the sale price of new homes being around £400,000. If housebuilders cannot achieve this level of pricing, then they simply won’t build the houses.

Affordable Housing Uplift

Some further adjustments are then made to lift the housing target 985 dpa for the HMA, or a further 24 dpa (504 in total) for Hart resulting in a total of 6,636 over the whole planning period. Even if this adjustment were accepted, this would still be easily accommodated on brownfield land in Hart.

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

2016 New Hart SHMA Figure 10.11 estimate of additional households in need

There are two issues with this approach. First, column G shows there is a net negative need across the HMA, but Rushmoor needs to find 84 dpa. These are arbitrarily shared amongst all three districts, even though there is no net need across the three districts as a whole. Second, the whole analysis appears to double count the housing uplift for market signals above in that the ‘concealed families’ are already accounted for in the market signals analysis.

Accordingly, we believe this adjustment should be removed from the calculation.

Jobs Growth Adjustment

The most egregious adjustments come from the jobs growth adjustments. The total housing requirement is increased to 1,200 dpa for the HMA. This results in 382 dpa for Hart or a total of 8,022 new houses over the planning period. This increase means it is likely we will have to allocate green field land for development.

We have a number of issues with this adjustment.

First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area.

Second, the projection of 1,200 jobs per annum is far in excess of the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.

Third, they use a very circular argument to account for the number of jobs. The argument is basically, the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs. So, they then decide we will need to import some extra people and those people will need houses. Clearly, this is not an expression of the ‘need’ for the district.

However, the population projections already assume inward migration from other areas and international migration from abroad. Note that since the Brexit vote, migration from the EU is likely to fall, so these projections may well overstate the level of international migration.

These additional people must be coming from other areas. However, we know from analysis of other authorities that they are also increasing their housing targets by around 42% above the demographic projections. So, the question remains, where will the people come from to live in the extra houses? All local authorities need to meet their own local needs, so if all local authorities plan for far more than they need, we will have too many houses, but we will have concreted over our countryside.

Essentially, we are being asked to concrete over our green fields to build houses for people who might move into Hart to fill fictitious jobs that someone thinks might be possible to create in Hart. And other districts should already be planning to house those people.

It is a farce. This adjustment to the housing targets should be removed.

2016 New Hart SHMA Conclusions

We believe a realistic housing target for Hart is around 6,000. This would meet the needs identified from the most up to date population projections and give a sensible allowance for additional houses to cater for ‘concealed households’ and the younger people who want to get on the housing ladder. Affordability will come from building more smaller properties and taking advantage of the Government Starter Homes Scheme.

This housing target will mean we can build all of our remaining requirement on brownfield sites and still have many brownfield sites available for future generations.

However, given the perilous state of the Local Plan, we can’t simply ask for this to be redone. We must argue in the consultation about the new Local Plan that the housing target in the SHMA is too high, and therefore the plan does not need to allocate as much green field land for development. We have no doubt that there will be a number of developers arguing for an even higher target.

The new Hart SHMA and appendices are available for download below:

Hart Rushmoor & Surrey Heath 2016 SHMA
Hart Rushmoor & Surrey Heath 2016 SHMA Appendices

 

 

 

 

Status of Hart Local Plan set out in email to parish councils

Hart District Local Plan delayed again

The current state of play of the Hart Local Plan was set out in an email to Parish Councils last week.  We reproduce it below with our commentary in [bold italics]

Dear All, I am writing to update you on the current position with regard to the Hart Local Plan.

The Council’s overall strategic position on the Local Plan was agreed in October 2016.  It is to:

“Seek to meet Hart’s full, objectively assessed need for new homes, subject to the inclusion of an appropriate contingency to allow for any delays or the non-delivery of sites, and that it will also seek to accommodate any demonstrated unmet need for new homes from its Housing Market Area partners, and additionally provide for essential infrastructure including a site for a secondary school”. 

We have a Local Plan Steering Group (LPSG) that was set up by Cabinet and comprises a small Core Group of Members (The Leader, the respective Portfolio Holders for Planning and Housing, all Group Leaders, and the Chairman of Planning Committee). The purpose of LPSG is to advise Cabinet on Local Plan matters. It is not a decision making body. LPSG meetings are not held in public but the meetings are not secret and the minutes of each meeting are reported to Cabinet. The meetings are also open to all Councillors to attend and Stephen Parker, as Chairman, has encouraged all present to participate.

The latest meeting in December (LPSG minutes attached) tested the Policy Planners recommendation that we should support a potential option (which we called Option 3a) that included a possible small new settlement, urban extensions and a balanced distribution of new homes across the District. [We believe this included Murrell Green, Grove Farm and Owens Farm to the west of Hook. We understand Winchfield and Pale Lane (Elvetham Chase) were specifically excluded]. A site for a secondary school was also identified. In principle Option 3a would have accorded with the strategic aims agreed by the Council in October 2016. If agreed it would have resulted in a draft Plan being progressed to Council at the end of January with a view to it all going out to public consultation.

Whilst Option 3a still lies on the table the consensus from the recent LPSG meeting was that Option 3d (a larger new settlement and distribution option) [We believe this brought Winchfield back into the equation. The likely timescales would probably mean that Grove Farm and some combination of Pale Lane and Owens Farm would be required] should be revisited [We understand the driving force behind this initiative was Concrete Community Campaign Hart, who seem intent on derailing the whole process]. This was because the recent Housing Options consultation had confirmed that the public’s first preference is for future growth to be focused on the delivery of a new settlement [Actually the council stated its first preference was for brownfield development, but did not give the public an opportunity to vote on that solution].  The least preferred option was for more urban extensions. The broad cross party consensus was that we should look to avoid delivering urban extension and Option 3d would in itself be an alternative way of delivering the strategic aims agreed by the Council in October 2016.

At the moment we are reflecting upon this. We are reviewing the two options and we will consult shortly on one of them. At the time of consultation we will offer a briefing to all Parish and Town Councils. We are also testing the need for any affordable housing uplift [This is the rumoured 2,155 extra houses to meet an alleged need for 800+ extra affordable homes] which is also an new approach that is being recommended to us by the Policy Planners. It does have an implication for how many new homes that we should built but it does reflect issues that have been raised by Inspectors at recent Local Plan examinations. We need to consider it further and a policy decision made by the Council about whether it agrees to follow it. This testing may require a little additional work and re-evaluation of delivery timescales and trajectories. More information is being submitted to help us with the evaluation.

In the meantime Officers are keen not to undermine the democratic processes by engaging in a public debate [!!!!!] in advance of the District Councillors themselves having formed a view about how they wish to see the way forward [Perish the thought that councillors be involved in a debate with the public] . There is absolutely no benefit in seeking to rehearse decisions that have not yet been made and I’m sure that everyone would agree that it would not be right for Officers to engage in what is in effect political speculation.

We understand form elsewhere the delay to the Local Plan will be 4-6 weeks, or longer. Given that five of the six weeks have already all but gone by since the LPSG meeting on 13 December, we shall not be holding our breath.