Havant Friends of the Earth - Observations on the 2036 Havant Draft Local Plan (DLP) 15th February 2018

HAVANT TOWN CENTRE

Previous plans and studies for the revival of Havant’s historic town centre have come to nothing while hideously inappropriate schemes in a designated conservation area such as 13-storey blocks of flats and change of use of a landmark historic building into a casino have been approved (and since failed) serve only to send out confusing messages about what Havant historic town centre wants to be. It is now proposed to re-draw the town centre boundary and find other uses for East Street with more listed buildings than any other in the borough. This looks suspiciously like an attempt to relegate what is essentially a regeneration challenge to the back burner.

The draft plan fails to specify how East Street (architecturally the finest in the borough) will be developed other than a vague commitment to a new Master Plan. There is little evidence of any consultation over the proposed new boundary with the 20 or more East Street businesses or their customers (including The Spring, the town’s main provider of arts and entertainment) The Meridian Centre does need to be repurposed on its upper floor for leisure activities like a new cinema to help the night time economy and fill the space vacated by the library if and when it moves (where?).

In the Market Parade area, the land at present allocated to car parking should re-designated as a public transport hub that could include the station forecourt area. The story of Havant town centre is that everything is mostly in the wrong place while the council has failed over years to make it an investible proposition for commercial property companies.

HOUSING

National housing policies are neither providing sufficient affordable quality homes, nor protecting ecosystem services nor ensuring homes are built to the right standards in the right locations. Increasing the supply without first controlling the price of land will not solve the housing crisis or reduce prices.

The council has used a standard process known as Objectively Assessed Need (OAN) in arriving at the number and type of accommodation required to meet future local needs. The calculations are based on a range of criteria that include population and household growth, employment and other demographics.

In summary the process is a reprise of an old predict and provide tool based on past trends and future forecasts. Havant council made itself a member of Partnership for South Hampshire (PUSH), a sub-regional association of local councils, which have commissioned various studies using consultants to estimate and allocate future housing needs across the sub region. Buried deep in the PUSH mindset (and Solent LEP) is the aim of increasing Hampshire’s Gross Value Add (GVA) and it sees building more houses as a pre-requisite to a growing workforce despite mounting evidence that AI and robotics will result in structural changes that in the near future could result in fewer jobs (Future of Employment Oxford University 2013). The PUSH consultants housing projections have been recommended to each member authority for formal adoption by its councillors. In Havant’s case, perhaps encouraged by the New Homes Bonus offered by government, the recommended numbers were simply accepted and questions about the number of units incorrectly put down to a government directive.

This left the council with the task of finding land to meet its self-imposed target and by all accounts this has now been accomplished at the expense of hundreds of acres of green field sites. In 2016 a successful appeal by a developer (McCarthy & Stone) on the grounds of an out of date plan (despite it having been adopted only 2 years earlier) against a decision to refuse an application plan galvanised the council into hastily producing new housing numbers ahead of a new Draft Local Plan (DLP). A Housing Statement with sites was published and put out for public consultation but despite over 800 mostly critical comments, it was approved by the council.

According to a nationwide study of built-on land by the BBC in 2017 46% Havant Borough land is built on compared with Chichester at 4%, East Hampshire 5% Winchester 4% and Fareham 38% While Havant is so far not quite among the most intensively developed areas outside the cities in South Hants it is rapidly catching up while development in some neighbouring authorities seems hardly to have happened.

The cost of buying new build in Havant is almost 11 times more than the average yearly per capita income for the area so many local residents are excluded from living in the town in which they were raised.  Evidence from Help to Buy and similar schemes suggests they may help some people get on the property ladder but also push up prices. The 9000 or so people registered on Hampshire Homes Register (1700 in Havant) and those in temporary accommodation are unlikely to benefit from the new homes envisaged in Havant’s DLP.

How many of the new homes will be affordable to rent (or buy) is not clear from the strategic market assessment but it can be assumed that those most in need of somewhere to live will not be helped by the DLP. In any event developers have the option of buying their way out of affordable provision.

The rentals sector has been left mainly to private landlords where rents are up to twice the cost of buying a home and often exceed the limit of housing benefit.

Havant ‘bold new strategy’ appears to build as many homes to buy as it can find land for irrespective of the impact on the character and sustainability of its landscapes without providing any real hope of helping local residents most in need.

SELF BUILD AND MODULAR

The DLP fails to mention community self-build and modular building for diversity and innovation – there are increasing numbers of people, communities, cooperatives and social enterprises who are looking to providing housing solutions, including self-build or modular design houses and co-housing solutions. This could bring diversity and innovation into a sector which is dominated by a few large firms. Pre-fabricated modular build also allows for much faster building, more efficient use of resources and lower costs. This approach should be championed and supported by local authorities like Havant.

SOUTHLEIGH

This 375 acre site, as farmland, is worth almost four million pounds. Conversion to development land is likely to deliver a capital gain worth hundreds of millions pounds to the private land owners. Progress towards development is dependent on a new road and other infrastructural improvements that will have to be funded by taxpayers. But why shouldn’t the primary beneficiary, in this case Southleigh Estates, contribute to the infrastructure cost from their massive capital gains windfall?

In the eighties the whole area was protected by a legal agreement between Havant Council and Southleigh Estates ‘in perpetuity’ guaranteeing no further development beyond Locks Farm between the Havant Council and Southleigh Estates. This has since been twice compromised with the addition of a crematorium north of Bartons Road and development on land west of Horndean Road and there are also further allocations within the area.

The components for the development of Southleigh, namely a willing land owner, a pro development-led council and so far, unnamed developer(s) are already in place so any further objections must await the arrival of a planning application. The council should work through its membership of the LGA and other bodies to lobby central government for a new land value community tax to achieve a fairer distribution of infrastructure costs. Finally, it is understood that of 2100 units scheduled for Southleigh 1100 would be delivered by 2036. It would thus seem beyond the scope of the DLP to allocate land for development beyond the 1100 units.

WESTWOOD CLOSE

This site was not part of the Housing Statement published and adopted in 2016. Situated beside the River Ems the site is an unwelcome and unnecessary insertion over a long distance footpath through a popular area which should otherwise have been listed as Green Space.

ENVIRONMENT& CLIMATE CHANGE

Havant’s natural environment encompasses almost every designation of protection that include SPA’s, RAMSAR, AONB and SSSI along with local nature reserves and over 100 Sites of Interest to Nature Conservation (SINC). Development along the scale proposed in Havant’s DLP will inevitably result in damage to nature as well as be potentially harmful to people and wildlife through the generation of more pollution, demands for water and waste treatment, traffic congestion and loss of most versatile agricultural land.

Apart from a headline statistics and generalisations the DLP has little to say about achieving an acceptable balance between meeting its housing quota and conserving and even enhancing the borough natural assets.

In 2011 Havant Council published a Local Biodiversity Action Plan (LBAP) to “provide a vision and a framework for future action to conserve biodiversity in Havant Borough. The LBAP provides Havant with a mechanism for meeting Green Infrastructure objectives to enhance existing biodiversity, restore habitats, mitigate for the impacts of development and reduce the effects of climate change”

Despite its laudable aims the LBAP is not even mentioned in the DLP other than a hint of a new biodiversity document in which the word ‘plan’ will be replaced by ‘strategy’. A plan is usually a series of specific steps whereas a strategy merely signposts the direction of travel. Neither is there any real acknowledgement that developers must be able to demonstrate a net benefit to biodiversity or ecological bonus said to be a key aim of the recent announcement by the Prime Minister as part of her drive for a greener Britain As a sea-facing community Havant is likely to be in the front line of climate change especially all types of flooding and rising seas around its 60km coastline including the increasing possibility of a rise in sea levels in excess of the forecast of approximately 60 cm by end of the century.

The sites shown in the DLP have been through a sustainability appraisal (SA) process and most have been deemed to be acceptable according to the council’s criteria and scoring methodology. This begs the question as the integrity of the process and suggests the need for an independent and critical oversight to discourage the view that the SA amounts to nothing more than a tick box exercise.

CYCLING NETWORK

While the importance of cycling is acknowledged in the DLP it needs even greater emphasis to build on the investments already made in Havant Borough’s cycle path network throughout the borough and publish a strategy for further development over the plan period. The aim must be to achieve separation from traffic wherever possible through smart design and make cycling a key component of an integrated transport assessment for the area whenever it is published.

TREES

One of the recognised ways to managing climate change is to plant more trees and hedges in the right place to remove carbon from the atmosphere. A significant number of trees are likely to be removed and thus degrade the present green infrastructure of the fields on which most of the new houses will be built. Some will be replanted by developers but those selected are often dwarf varieties, much less robust and for carbon storage and much less efficient than the trees they replace.

SUSTAINABLITY

The DLP highlights the importance of adaptation and mitigation to manage the consequences of global warming but few specific measures are proposed apart from exploring a very modest district heating scheme in the civic campus area, there are no land allocations shown or plans for building renewable energy capacity including charging points anywhere in the borough. Home Quality Mark star rated homes may go some of the way towards replacing the excellent but sadly withdrawn Code for Sustainable Homes but the take up by companies so far nationally is mostly among SME’s rather than large corporate building companies engaged in Havant.

GREEN SPACES

It is understood that the areas listed in the DLP may be extended although the draft policy written around them appears to be woolly and exposed to potential challenges by developers offering facilities in exchange for more houses.

CONCLUSION

The 300-page plus draft document plus supporting evidence is a formidable challenge for any individual and especially elderly residents to read online or in the local library. The ‘What Next’ documents are helpful but at best are just a summary while the full drafts drills down into important detail. Presentations and road shows from officers at residents’ gatherings help but more should have been done to engage the public at interactive events led by local councillors.

The overall impression of the Draft Plan is that it is rushed, lacking in certain key details on transport, infrastructure and offers little more than a top-down blueprint for future housing driven by the council’s leadership’s aim to accelerate the urbanisation of Havant Borough. Ironically the council seeks to justify the speed of the exercise by pointing to threats from developers to bring forward applications based on the McCarthy & Stone precedent.

In effect the council has got in before the developers by committing sites that may have been successfully refused as separate applications. The council repeatedly and transparently claims that housing numbers are set by the government when according to government sources they are firmly the responsibility of local councils.

The local MP and council leadership are promising thousands of high end new jobs from the Dunsbury Park development on the basis of one translocation of a distribution centre of a Havant based business (Fat Face). Some residential development on Dunsbury Park site could save green field sites elsewhere in the borough. Havant Town centre is a casualty of changes in consumer behaviour but this has been known for years and little has been done while one of town’s oldest streets has been left to wither. Piecemeal conversions undermine the area’s conservation values. The draft plan suggests little change.

The impact of major development on Havant’s already stressed green infrastructure and ecology on as well as rising seas and surface flooding is filed under ‘sustainability appraisal’ which in almost every case is judged satisfactory and/or a matter to be resolved through mitigation. The council needs to strengthen its involvement with local ecology and add teeth to mitigation measures by making it a condition of planning that an ecological clerk of works is appointed on all major sites.

The strap line adopted by the council of ‘leaving no stone unturned’ and ‘open for business’ have simply encouraged land owners and developers to declare a permanent open season for development in Havant.

More information of Friends of the Earth’s position on housing

https://friendsoftheearth.uk/sites/default/files/downloads/environmental-socially-just-agenda-housing-48776.pdf

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