[These arguments have been expanded and refined on this page. ]

The following questions about the housing allocation for Hart were asked at the council meeting on 27 November.

This post refers to the Strategic Housing Market Assessment and its Appendix that are published on the Hart Website here:

(http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/HRSH%20Consultation%20Draft%20SHMA%20May%202014.pdf  and

http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/HRSH%20Consultation%20Draft%20SHMA%20Appendices%20May%202014.pdf ).

Process

 

• Background: I would like to understand the process that was adopted to select Wessex Economics to conduct the SHMA. Their website (http://www.wessex-economics.co.uk/about/ ) indicates that they have extensive experience in the property sector, but the principal’s background is with DTZ a leading provider of services to investors and developers.  I am concerned that such a company will be biased towards “development” and not sympathetic to the needs of local people or the environment. Question:  What process was followed to select Wessex Economics and what process was followed to determine that Wessex did not have inappropriate relationships with or financial interests in any housing developers?
• Background: In the appendix (A1.2), the process for stakeholder engagement is set out. The only people consulted were from local authorities or from developers and housing associations or their representatives.  If the main people consulted are the salivating developers, it cannot be a surprise that their input errs towards the need to build more.  Question: How can the SHMA be a truly Objective Assessment of Housing Need if the main consultees have a vested interest in the outcome?
• Background: The SHMA is still in draft form on the Hart website. Question: Why is such a fundamental document as the Strategic Options for Housing Growth is being based on a flawed, unchallenged, draft document?
• Background: Section 1.6 of the SHMA says “For a local plan to be considered sound in terms of overall housing provision, it first needs to have identified the full, objectively assessed need for housing in the housing market area. Local authorities then need to meet these needs in full and demonstrate how they will be met, or provide robust evidence that they cannot be delivered.” Question: What evidence is the council producing to demonstrate the objectively assessed housing need is not deliverable?
• Background: The starting point for the SHMA is the CLG forward population projections. These essentially project forward past trends.  Question: Notwithstanding this is the “preferred approach” in the NPPG, what evidence is there that basing the future need of an area on past population growth is the best or most desirable approach and has the council considered working with other councils to challenge the government mandated approach in the courts?
• Background: Most of the consultation feedback from developers was against Option 4. The only developer in favour was Barratts and they produced an expensive glossy brochure as part of their submission.  Question: Please set out all of the contact between the council (meaning council officers and councillors) and Barratts in the period from one month before the SHMA was commissioned and 31 October 2014, and all of the contact between the council (meaning council officers and councillors) and all other significant developers for the same period.

 

Content

 

There are a large number of tautologies and flawed assumptions in the SHMA which I would like to draw out and thus challenge the overall conclusion.

 

• Background: Surrey Heath and Rushmoor are both more highly developed than Hart.  Question: What is the rationale for grouping largely rural Hart with such heavily built up areas?  Would it not be more appropriate to group Hart with more rural districts to the west and south?

• Background: The report uses as it starting point for the OAHN the official government projections for the number of households in the Housing Market Area (HMA) that includes Hart, Rushmoor and Surrey Heath which states that the total number of new homes required per annum is 790. The report then states that the ONS usually understates these requirements so it makes an arbitrary adjustment upwards to 925 homes per annum.  However, the government website (https://www.gov.uk/household-projections-notes-and-definitions-for-data-analysts ) states that “The current methodology in England reflects work to improve the household projections outputs and methods to better meet user needs”.  Question: What is the justification for a small economics consultancy to challenge the official government figures when the government itself asserts that it has improved its methods and outputs, especially when the assumption leads to an additional 135 dwellings per annum being required across the whole HMA over a 20 year period, a total of 2,700 dwellings?
• Background: The summary in section 3 notes that the level of household growth in Hart at 10% over the past 10 years has been higher than the regional and national averages. This growth in households can only have been accommodated by new building (e.g. Elvetham Heath in Fleet and St Mary’s Park in Hartley Wintney).  Question: Why is it that we need to base our future housing need on past rates of development that were above the regional and national average, this can only lead to the conclusion that over time, more building will lead to even more building which is absurd and cannot be “sustainable”?
• Background: Section 7 of the report deals with migration into and out of the Surrey Heath, Rushmoor and Hart Housing Market Area (HMA). Figure 7.5 draws a correlation between migration and housing completions.  In essence, if you build more houses more people will come to the area.  This is perhaps an obvious point.  For Hart in particular, they use the years of 2005-2010 as the years that are most representative of the trend of migration (years in which significant building in Elvetham Heath and other places was taking place).  More recent trends in Figure 7.4 shows a slowdown of migration and indeed a net outward migration from Hart during 2009-2011 and a net outward migration from the whole of the HMA in 2011-12.  In essence they are saying in para 7.35 that we must assume levels of house-building during the credit boom (itself hardly sustainable) to support the population growth of that time in order to predict future population growth for which we will then need to build even more houses.  This is an absurd tautology which leads to a gross distortion of underlying need.  Question:  Why are we basing future need on the years with the highest inward migration that happened during an unsustainable credit boom, and not the most recent years with lower migration which will lead to a more economically and environmentally sustainable solution?
• Background: Figure 7.7 shows that the trend in household size as measured by the census is slightly upward for the period from 2001 to 2011. However, all of the forward projections reverse this trend and predict a further fall in average household size without any justification.  Wessex have taken some mid-point of the CLG projections.  Question: Why can’t we base our projected household size on the most recent Census data rather than data that is 30 years old and thus reduce our OAHN?
• Background: Para 7.63 assumes as its base level a higher rate of future job growth (700 p.a.) in the future than was achieved (650 p.a.) during the exceptional, unsustainable boom years of 1998-2008 when our rate of building was already above regional and national averages. Paras 7.68 and 7.69 then further exaggerate the future level of job growth by suggesting it could rise to 1,560 jobs per annum, more than double the Scenario 1 estimate which is based on employment growth that occurred during the largest, unsustainable credit boom in history.  The final jobs growth based estimate used is then a mid-point between the already over-estimated base assumption and the wildly exaggerated high end projection.  Question:  Why aren’t we using employment projections based on more sustainable economic and environmental assumptions which probably ought to be lower than those achieved between 1998-2008?
• Background: Para 7.81 sets out six ways in which jobs can increase without increasing the need for additional housing. Para 7.83 says the modelling has taken account of only one of those factors.  This again has the impact of increasing the housing stock required in the OAHN.  Question: Why can’t we take account of all six ways in which jobs can increase without building more housing?
• Background: Figure 8.9 suggests Hart needs to build around 260 affordable homes per annum if the backlog is to be cleared in five years as part of the overall 370 homes per annum required.  Question: Please explain how building a Barratts estate new town in Winchfield will address this affordable requirement?
• Background: The demographics of the district are changing. According to the SHMA, by 2031, there will be an additional 10,000 people over 60 (including more than 6,850 over 75) expected to be living in the district and an extra 3,620 people who will be suffering from dementia or have some sort of mobility problem. Section 9 of the SHMA suggests that future housing stock should be built to broadly reflect the existing stock. Evidence from developers such as Churchill and McCarthy and Stone suggests (http://www.mccarthyandstone.co.uk/documents/research%20and%20policy/oorh%20full%20report%20may%202011.pdf  ) that remote estate locations are not good places to house the elderly and infirm.  Question: What evidence base is there to suggest that the needs of the future population will be met by past housing stock?  What evidence has the council collected to determine the best types of accommodation and the best places to build those types of housing to meet the needs of the elderly and infirm?
• Background: Para 7.119 states the following “These market signals point to the need to identify and address the demographic and economic need for housing; they do not themselves provide a quantifiable need for housing (and indeed there is no recognised methodology for this)”. Question: If there is no recognised methodology for providing a quantifiable need for housing, why are we following an approach that is artificially inflating the housing need for the area that will inevitably lead to the destruction of the most attractive parts of the district?
• Background: The Localism Act requires local authorities to maintain a list of assets of community value which have been nominated by the local community. Question: Where can the Hart register of assets of community value be found, and can I nominate the Winchfield area as an asset of community value?
• Question: Can the council please commence activity to protect the Winchfield area as Green Belt on the following grounds:
  • To check the unrestricted sprawl of built-up areas.
  • To safeguard the surrounding countryside from further encroachment.
  • To prevent neighbouring towns from merging into one another.
  • To preserve the special character of historic towns.

• Background: The information on the environmentally sensitive areas of Hart can be found here: http://www.hart.gov.uk/sites/default/files/4_The_Council/Policies_and_published_documents/Planning_policy/SA%20Scoping%20Appendix%203%20Baseline%20Information.pdf (p20).  As can be seen from the map, the proposed development is within the Zone of Influence of the Thames Valley Heath SPA; contains numerous Sites of Interest to Nature Conservation (SINCs) and is so close to the SSSI sites at Odiham Common and Basingstoke Canal that it must be damaging to those sites.  Question:  Why is the council intent on pursuing a preferred strategy that will in all likelihood fall foul of legislation to protect our environment?