SMASH submits its response to the EHDC Local plan consultation!

Please see below a summary of SMASH's submission to the local plan. For the full version of the submission go to our website https://www.smashonline.co.uk

Thank you for your continued help and support.

EXECUTIVE SUMMARY

Background

East Hampshire (EH) is a rural district in the Southeast of England with a population of c.125,000, of which a whopping 24% are aged 65 and over. The population growth and change for EH for the period 2021 to 2038 shows that the fastest age range for growth is the older age range of 65 plus which is predicted to grow by 43%. This means that EHDC needs to take a strategic approach to addressing the housing needs of the population which it serves.

Housing and Economic Needs Assessment ( HEDNA ) 

The HEDNA 2022 data shows the predicted and current population change, using this data the biggest area of housing challenge for the community will be the 65+ age group. This implies that 1–2-bedroom dwellings will be needed and where possible within a short and manageable reach of facilities (shops, healthcare provisions, banks, pharmacy.) Taking into account the Gove consultation, older peoples housing needs should also include care homes, independent living, and residential care.

Housing needs and numbers

SMASH believes that EHDC has an opportunity to review the housing need for the whole district. If EHDC takes on board the potential changes in regulation as a result of the Gove consultation, EHDC can reduce the housing numbers and only build what it needs to build based on true need. That number should be determined with input from local communities and should be sensitive to local constraints and concerns. SMASH would expect to be actively involved with these discussions.

Further, Gove says that building at densities which are significantly out of character within an existing area may be a justification for not meeting housing needs in full. We believe that our villages need special protection so that the character and the residents lifestyles are not irreversibly damaged.

Affordability ratio

SMASH believe that the concept of 'affordability ' needs an urgent review. The current Affordability Ratio artificially inflates the amount of housing numbers required. This is because the current methodology uses the national income of a single individual. We believe that a weighted combined “new household” income of £35,082 should be taken into account to assess this ratio as many new households consist of two people.

Further we also believe that affordability should be based upon what level of mortgage a lender might be prepared to loan - it would be better to be guided by mortgage lenders but typically a lender will give 4.5 x the average household income.

SMASH also believe that the proportion of ‘First Homes’ (where a minimum of 30% discount is given to the first-time buyer)  should be increased on larger developments.

Over Delivery - our recent delivery performance

Over 500 houses have been delivered in FM and Medstead in the last 9 years. In the southern part of Medstead alone, in 2017 and in 2018, 133 and 151 respectively were built. This is more than the TOTAL annual housing number allocated to the WHOLE of the SDNP......This does not seem to be fair or equitable and we expect EHDC to take full account of this and not burden these two villages, but especially Medstead, with more houses.

Petition and feedback.

Within the space of a few weeks, over 1800 petitioners in FM and Medstead, expressed their deep concerns and objections to any notion that EHDC may decide to build large scale housing developments in our villages. The key reasons given for the opposition and objections included – over delivery already, ruination of the villages and village life, unacceptable increase in traffic and pollution, loss of green fields and precious wildlife and facilities being swamped and unable to cope.

Settlement Hierarchy

SMASH have noted that EHDC are proposing that the settlement hierarchy that FM and Medstead currently belong to (tier 3) is changed to a tier 2. The arguments for doing so are flimsy and artificial. If EHDC press ahead with this, it will mean that EHDC have opened the door to building far more houses in our settlement. We and those we represent are strongly opposed to this underhand and sneaky proposed change. Whilst we accept that the concept of a 20-minute neighbourhood is a good one ( i.e., one where the residents can walk to local amenities ) EHDC’s proposal absolutely does not fit FM and Medstead at all. The strong sense is that EHDC have contrived to make the tier boundaries so wide and uneven that FM and Medstead are moved up into a higher tier.

For the avoidance of doubt - we are not a 20 minute nor even a 30-minute neighbourhood. There is no 'as the crow flies route' and EHDC have not taken account of the topography and the long hill climb that many residents in Medstead face to reach the majority of the local amenities.

FM and Medstead are not in any way comparable with Horndean (a Tier 2 Settlement ) and we strongly object to this part of the consultation.  

Our recent local travel survey should be read, and the findings noted. The majority of respondents use a car to access most amenities, and this cannot and will not change because there is little employment or facilities here.

The Options on where houses should be built

Smash note the 4 options put forward by EHDC on its spatial strategy.

We do not believe that the options put forward are the right options. They are too simplistic and /or contain too little information for meaningful consultation. However, SMASH would want to see serious consideration being given to:

• Housing numbers to match housing needs both in terms of numbers required and the types of dwellings,
• There should be no large housing estates – the 600+ houses in semi-rural villages is no longer a justified strategy,
• The housing numbers must take into account the significant growth of the 65+ age group.
• The fact that FM and M have absorbed over 500 houses in the last 9 years and therefore do not get hit with more than an absolute minimum.
• That any new housing development is situated close to established facilities such as a choice of shops, full healthcare provisions, employment, and social amenities such as cafes, restaurants, sports centres, banks, clubs, and societies. This is the only way of avoiding the use of the car.
• EHDC should first be able to demonstrate that it has forensically examined brownfield sites and its own land before attempting to build on any green land and fields.

Department for Levelling up

On 22nd December 22, the proposed revisions to the National Planning Policy Framework was launched. The consultation period will end in Spring 2023, but the proposed revisions have some very important implications for EHDC and for its planning and housing strategy. It would be prudent to wait for 2-3 months for the consultation to end and the government to announce the changes that it proposes.

There are key changes which will impact the current Local Plan Consultation. This paper highlights the proposed changes which demonstrate that EDHC need to rapidly review and reposition its emerging strategy. Herewith the key proposals :

• The removal of LPAs to continually demonstrate a 5-year housing land supply, 
• That uplifts to establishing housing requirements should be prioritised to brown field or under utilised urban sites (and not rural locations),
• Housing needs for older people should be widened to include retirement and housing with care and care homes,
• Past over delivery can be deducted from the housing requirements,
• Building at densities significantly out of character with a local area may be justification for not meeting full assessed housing needs. We believe that this would apply to FM and Medstead,
• The tilted balance test is removed and replaced by a new test of whether adverse impacts are likely to significantly and demonstrably outweigh the benefits of any development.
• The proposed removal of the requirement to satisfy 'unmet' need from neighbouring authorities  – thus EHDC will no longer have to consider the National Park and it's housing needs. Your question in the survey refers to this.

Given the above and the positive impact that the changes could have for the population of EHDC, we think it would be irresponsible for EHDC to continue to progress the local plan until Michael Gove's consultation and NPPF revisions is completed.