Ref No

Main points made by respondents

Strategic planning officers' response

1.

The figures for housing supply may be underestimates as at least one authority has yet to include new housing allocations in its Local Plan and the urban capacity studies are under-cautious in their estimates.

Later this year the remaining local plans will be published in draft and the strategic planning authorities will undertake a check on the consistency and rigour of the urban capacity studies. This will enable more robust information to be included in next year's Monitoring Paper.

2.

Many council estates need to be brought up-to-date, which could release under-used land for housing and thus increase total housing supply.

Opportunities for infilling within local authorities' housing estates should be included within urban capacity studies. It seems unlikely that local authorities will have the resources in the foreseeable future for comprehensive redevelopment of estates at higher densities.

3.

The conclusions of the Monitoring Paper are welcome and supported: they demonstrate the value of the monitoring process.

This support is welcome.

4.

The Paper is helpful and lucid. It is a good example of the monitoring work which SEERA hopes to encourage across the whole Region.

These comments are welcome.

5.

The need for affordable housing may become so acute as to justify additional land being released.

This point is recognised; however, the SPG on which the Monitoring Paper is based specifically states that "any shortfall in meeting affordable housing needs cannot normally be a reason in itself for releasing any of the reserve provision" (paragraph 2.22).

6.

Additional information should be provided in future editions of the Monitoring Paper on affordable housing and dwellings built prior to 2001, including reasons for the recent decline in housebuilding.

This information will be included in the separate, more comprehensive Structure Plan Monitoring Report (see item elsewhere on the agenda).

7.

If there are problems foreseen in the MDAs coming forward on the expected timescale, then the strategic planning authorities efforts should be put into ensuring the MDAs do come forward, rather than into promoting the release of reserve sites.

The recommendation to this Panel reiterates the previously expressed call for local planning authorities to expedite the preparation of their local plans including, where relevant, the MDAs.

8.

Nature conservation constraints, especially the Thames Basin Heath's Special Protection Area, may prevent the assumed 1,000 dwellings being built on Project Connaught, Rushmoor Borough. It is therefore questionable whether reliance should be placed on this development in preference to the release of reserve sites which have been subject to the Local Plan process.

Rushmoor Borough Council is considering the scope for development as part of its draft SPG for Project Connaught, on which consultation recently took place. Refined information on Project Connaught will be included in next year's Monitoring Paper.

9.

The Paper adopts a sensible and pragmatic approach which is generally supported, particularly the realistic view taken in relation to uncertain sources such as urban capacity studies.

This endorsement of the paper is welcomed.

10.

A district-by-district breakdown of the supply and requirements would have been useful, including an explanation of the causes of the apparent overall surplus of housing supply.

See response to comments 6 and 18.

11.

The urban capacity studies should be started again, but this time with a standard, consistent methodology by each district so that the results can be analysed on a compatible basis.

The check by the strategic planning authorities this autumn of all the urban capacity studies will identify the extent of any incompatibilities. The need for any fresh studies will emerge from that verification.

12.

The Structure Plan is increasingly out of date in respect of subsequent PPGs and studies. It would be sensible and courageous to tear up the Structure Plan and start again.

This view is not accepted by the strategic planning authorities. GOSE confirmed earlier this year that the Structure Plan is in line with the key subsequent national guidance - PPG3 `Housing'.

13.

Eastleigh Borough Council has no intention of providing an MDA so this should be omitted from the overall supply.

Eastleigh Borough Council will need to address the County Council's objection to the shortfall in housing provision in its first deposit draft local plan when it prepares its second deposit draft later this year. Next year's monitoring paper will take account of the content of that second deposit local plan and its implications.

14.

Local planning authorities should no longer be required to identify specific reserve housing sites.

Although this year's Monitoring Paper concludes there is no case for releasing any of the reserve sites now, the paper makes clear that better information in future years may indicate the contrary. Therefore it is still necessary for local plans to identify reserve sites in case they are needed to be released in future.

15.

This is the first year of this new 'monitor manage' approach so inevitably there is a degree of uncertainty. The development industry should therefore take the findings on trust and give the process a chance.

This comment endorses the overall approach of the Paper.

16.

There are no reserve sites in any adopted plan as yet. Local plans are unlikely to produce usable reserve allocations until 2005/06.

This highlights the need for local planning authorities to expedite the preparation of local plans (as proposed in the recommendation). It also endorses the importance of looking several years ahead when monitoring and managing land supply.

17.

The Paper's assumption that the MDAs will come on line in 2006 is questionable, bearing in mind the major infrastructure and lead-in times required. Eastleigh's draft local plan makes no provision for an MDA; Winchester's local plan (West of Waterlooville MDA) will not reach second deposit stage until late 2002; Basingstoke and Test Valley (Basingstoke and Andover MDAs) are not expected to place their plans on first deposit until late 2002. The majority of these plans will not be adopted until 2005, and there is no evidence of proactive master-planning going on to facilitate an early release of the MDAs.

Additional information will be available to make a better judgement in next year's Monitoring Paper on the timing of development of the MDAs.

18.

The Paper does not provide an analysis at sub-area level despite the SPG 'Implementing Policy H4' saying that it would do.

The SPG states that sub-area and district level analysis will be undertaken if monitoring at plan area level indicates a need to release some reserve provision. As this year's monitoring paper concluded that at plan area level there is no justification for releasing any reserve provision, it was not necessary to continue the analysis on to sub-area and district level and this was excluded for brevity. See also response to comment 6 above.

19.

The Paper shows a significant oversupply of sites for new dwellings; current shortages in supply must therefore be due to the housebuilding industry and not the planning system.

Work is underway to establish the reasons for the current low rate of housebuilding. The findings will be included in next year's Structure Plan monitoring documents.

20.

The conclusion at paragraph 4.9 of the Paper implies that urban capacity site implementation will require more proactive involvement by councils in properly identifying sites and possibly using Compulsory Purchase Order powers: an approach planning authorities have yet to adopt.

The development of brownfield sites is often more complex and challenging than greenfield sites, and may require a more active involvement by local planning authorities.

21.

Despite its title as a monitoring paper, it provides no information for 1996-2001, the first five years of the Structure Plan period. The shortfall in housebuilding over that period compared to the 1994 version of RPG is not addressed.

Information on housebuilding during the first five years of the Structure Plan is included in the wider Structure Plan Monitoring Report to be published this summer (see item elsewhere on the agenda). The rate of housebuilding for 1996-2001 (average 5,350 per annum) was slightly above the Structure Plan's housing provision. That rate of building was endorsed by the Secretary of State when the Structure Plan was finalised in 1999, and can thus be regarded as superseding, in respect of Hampshire at least, the 1994 RPG. In any event, there is no requirement or facility within Policy H4 nor the SPG to release reserve sites so as to compensate for any low past rate of housebuilding.

22.

The Paper does not address the monitoring indicators with sufficient objectivity or critical analysis. It makes generalised and unsubstantiated assumptions, and glosses over key issues. As a consequence, its conclusions are misplaced.

Publication of the Monitoring Paper, even if not perfect, is a step forward in itself. Next year's edition will contain more robust information and assumptions, taking account of the specific improvements suggested by respondents.

23.

The total of 31,367 dwellings on large identified sites will not all be built by 2011 for various reasons, including delays in site development caused by PPG3, the Greenfield Land Directive, call-in of applications by the Secretary of State and recent changes to PPG25.

This issue will be explored further in next year's edition of the Monitoring Paper. This year's edition gives the best information currently available.

24.

The Paper's assumption that all small sites will be developed flies in the face of past experience. Large numbers of small site planning permissions lapse as ownerships change hands or because they were merely valuation exercises. Completions dropped between 1997/98 and 2000/01; the trend is downwards whereas the Paper assumes they will increase.

Meeting the policy figure in RPG will require a significant increase in housing completions which would be a reverse of the trend over recent years. It is to be expected that small sites will play a major part in this upturn in housebuilding. Even if a proportion of small sites was assumed not to be developed by 2011 for the reasons stated, total land supply across the plan area would still be adequate in relation to Structure Plan and RPG requirements.

25.

The Paper accepts the districts' urban capacity study results at face value. No checking has been done on whether they conform with Government guidance nor the strategic planning authorities' own guidelines. Even a cursory glance at the majority of studies shows they do not conform to either and are woefully inadequate as tools to predict the rate of future development on windfall sites.

The need to check the consistency and credibility of the urban capacity studies is recognised. The strategic planning authorities intend to undertake that work in the autumn, so that next year's Monitoring Paper can include more robust figures for urban capacity.

26.

A more realistic assessment of windfall site development should inform decisions on the release of housing sites. Details of past rates of windfall site development should have been included in the Paper, and used instead of urban capacity study estimates.

The advent of urban capacity studies marks a move away from the use of windfall allowances based on past rates to a more systematic approach. This is the Government's preferred method for assessing the potential contribution of such sites to housing land supply.

27.

A discount should be applied to the assumed supply of large and small identified sites in order to avoid the risk of over-estimation. The normal practice is to assume that 10-15% of sites will not be developed during the plan period.

This idea will be considered in preparing next year's Monitoring Paper.

28.

The Paper is over-optimistic in its assumptions about future housing land supply. The reserve sites are needed now and this Panel should sanction their release.

This conclusion is not accepted. Future monitoring may indicate there is a need to release some of the reserve provision, but to sanction their release now would be precipitous and premature.

29.

Future editions of the Paper need to be more robust so that district councils have a firm basis to release all or part of the reserve provision.

The need to improve the robustness of future papers is accepted.

30.

Housebuilding fell between 1997/98 and 2000/01, yet the Paper assumes a rate of building during 2003/04 which is 79% above that achieved in 2000/01. This is extremely over optimistic.

This will be looked at again in next year's monitoring paper, when housebuilding figures for 2001/02 will be available, which will give an indication of whether, and how fast, housebuilding is increasing.

31.

The implementation of the MDAs should be expedited to ensure they are all completed by 2011.

See response to comment 7 above.

32.

The uncertainty about future housing land supply highlights the importance of identifying reserve sites in local plans so that they can be released quickly if necessary.

Agreed. The recommendation to this Panel reiterates the call for local planning authorities to allocate sites for all the reserve housing provision.

33.

The Paper should provide a district-by-district approach. The Paper's county-wide approach allows one district to offset their housing requirements into neighbouring districts where greater urban capacity exists.

One of the underpinning principles of Policy H4 is that urban capacity in one district can be used to obviate greenfield development in another. Government guidance in PPG3 endorses such an approach.

34.

The MDAs must be expedited in order to deliver completed homes from 2006. Reserve sites should not be released solely to compensate for district councils who delay the identification of MDAs.

The need to expedite development of the MDAs is agreed - see response to comment 7 above. This would help obviate the need to release reserve sites.

35.

The need to link the distribution of housing to variations in housing demand and economic activity is not addressed in the Paper.

Housing demand and economic activity are not amongst the factors which Policy H4 says should influence decisions on whether to release some or all of the reserve provision. The SPG states that in the event that a decision is made to release reserve provision, then the strength of the housing market and local labour market considerations will be factors in deciding where to make that release.

36.

The document fails to show how the RPG housing requirement will be distributed at district level.

This is not part of Policy H4 nor the process of its implementation set out in the SPG.

37.

The Paper fails to assess past and projected requirements against market considerations, but only against the baseline Structure Plan requirement.

See response to comments 35 and 36 above.

38.

If a local authority provides its baseline dwellings, then total housing need will have been met and no further sites should be released.

The Structure Plan makes clear that local planning authorities must allocate sites for both the baseline and the reserve housing requirements.

39.

The results of the completed urban capacity studies vary so widely as to cast doubt on whether all have been sufficiently rigorous and consistent in approach. The strategic planning authorities' review of them should identify such inconsistencies and give more confidence to next year's Monitoring Paper.

Agreed.

40.

Section One of the Paper which sets out the policy requirements could usefully include advice in PPG3 and RPG about the presumption that previously developed sites should be developed before greenfield sites and about the phased release of sites.

This will be included in next year's Monitoring Paper.

41.

Dowds Farm, Eastleigh is a greenfield site and so is incorrectly included in the figures for urban capacity, which should only contain brownfield sites.

Agreed.

42.

The Paper could usefully show the proportion of total supply which is on brownfield sites.

This information will be included in the wider Structure Plan Monitoring Report (see item elsewhere on the agenda) and will be added to next year's version of this Paper.

43.

Supply figures for each of the three geographic sub-divisions of the plan area would be useful. Whilst it is clear that no release of reserve sites is necessary for the plan area as a whole, this may not be the case for each sub-division.

See response to comment 18 above.

44.

As total supply appears to exceed requirements, the release of those sites will need to be carefully managed to ensure that previously developed land is developed before greenfield land, for example, through phasing policies. It may be appropriate for the County Council to offer advice on that management of land supply to ensure, for example, a consistent approach across the geographic sub-divisions. This could be incorporated into future monitoring papers.

This will be considered in the preparation of next year's Monitoring Paper.