Archived decisions

1

Bell Cornwell Partnership

2

Hawthorn Kamm

3

The JTS Partnership

4

Centrex Strategic Land Ltd

5

Fareham Borough Council

6

Winchester City Council

7

Barton Willmore on behalf of Taylor Woodrow Dev Ltd

8

Phillips Planning Service

9

Gosport Borough Council

10

The Berkeley Group

11

Chancellors Planning

12

Terence O'Rourke

13

Adams Hendy

14

RPS Planning, Transport and Environment

15

RPS Planning, Transport and Environment for Bovis

16

RPS Planning, Transport and Environment for David Wilson Homes and Persimmon

17

Winchester City Residents Association

18

Charles Planning Associates

19

Persimmon

20

House Builders Federation

21

Hampshire Greenfield Alliance

22

CALA Homes

23

Economic Development Consultant

24

Government Office for South East

25

Council for Protection of Rural England

26

Basingstoke and Deane Borough Council

27

Save Barton Farm Group

28

Winchester Landscape Conservation Alliance

29

East Hampshire District Council

30

Test Valley Borough Council

31

South East England Regional Assembly

Respondent ref

Nature of comment

Response by Strategic Planning Authorities (SPAs)

Actions Arising

1, 16, 20, 23, 29

New Paper contains more relevant detail than previous report

Welcomed.

2

Welcomes date of publication as it is close to the November publication date previously agreed by the Strategic Planning Authorities.

Noted.

1, 4, 7, 11, 13, 15, 16, 20, 22

The Paper fails to rectify the significant shortfall in completions over first 6 years of Structure Plan period. It therefore fails the Plan Monitor and Manage (PMM) approach and is fatally flawed. The Paper seems to reject previously accepted philosophy and reinterprets the figures, contradicting both the RPGs and its own Structure Plan, in an attempt to `brush under the carpet' a significant shortfall of nearly 3,200 dwellings during 1996-2001.

RPG issued in 2001 supersedes the RPG issued in 1994. Structure Plans are required to adopt the provision set out in the new Guidance until such time as any different rate is adopted following review of the Guidance. GOSE has confirmed that there is no requirement to address any shortfalls arising from 1996 -2001 period.

2

The housing market continues to overheat partly as a result of too few houses being built (as noted in the low completions study). By not bringing forward additional sites the SPAs have abdicated their responsibilities.

Much greater emphasis is now being placed on the `manage' part of PMM by the planning authorities in Hampshire e.g. Basingstoke - and this should result in an increase in dwellings supply in the next few years.

22

The Paper is presented as a fait accompli, structured to `conclude' that no reserve sites are recommended for release. Planning authorities must begin to acknowledge that their deliberate suppression of supply through their manipulation of the planning system is one of the principal causes of the continuing and worsening `affordability crisis' in the County.

Noted. See above.

1, 3, 4, 13

Note that completions undershot the 2002 forecast. There is no reason to expect that future completion rates will match those forecast in 2003 Paper. Very tight `margin of safety' for completions to 2006.

Forecasting is not an exact science. The accuracy of the 2003 forecast will only be known later this year.

5

The forecast of annual dwelling completions are considered to be more realistic than previous forecasts.

Noted.

6

Table 2 gives a misleading impression of the performance of authorities that have a significant part of their land supply within Major Development Areas (MDAs) as they require long lead in times. Further consideration should be given to presenting information on housing completions by district to exclude the MDA component.

This is a fair point. However, the Table simply reflects the actual position and links in with the RPG annual requirement. Local Planning Authorities should seek to manage the remaining components of their housing land supply and seek to bring forward, where possible, other sites to bridge any shortfalls whilst developing their MDAs.

13

Contrary to the view of the SPAs, reliance on the baseline requirement only is not sufficient to meet RPG.

Whilst not being complacent, if all planning authorities delivered their baseline requirement as a minimum in 2001- 02, the additional dwellings built in some parts of the Hampshire would have almost met the County RPG requirement.

27

Revisions of increased densities now require 30-50 dwellings per hectare. This should result in baseline sites accommodating more dwellings.

The figures used in the Paper already account for an increase in density.

24

Table 3 shows there is sub-regional variation in completions since 1996. In the light of the CPA requirement for `balancing housing markets', the SPAs and districts should consider the implications of this variation for the housing market, especially the provision of affordable housing.

The under provision in the north of the County is inevitably suppressing the number of affordable dwellings that would be built if overall completion rates were higher.

3

Note that the North Hampshire sub-area has underperformed. Future sources of supply (MDA & UCS) likely to come on stream later than forecast. Bringing forward greenfield sources will enable the deficiencies quicker.

Noted. Local planning authorities should be applying PMM to bring forward suitable sites for development if required.

6

Further clarification is required of the apportionment between the 'northern Hampshire' and 'south-east Hampshire' sub-areas of the Winchester baseline requirement. Officers had assumed a roughly 50:50 split, with Winchester itself and areas to the north falling within northern Hampshire, and areas south of Winchester being within south-east Hampshire (although parts may relate more to south-west Hampshire!). The explanation of a 90:10 split contained in the Monitoring Paper does not seem appropriate.

The splits were introduced into the Housing Land Supply monitoring information for 2001-2002. Further discussion is required with Winchester and East Hampshire Districts in relation to the apportionment between the different sub-areas.

Yes

29

There is a contradiction between Policy H4 of the Structure Plan which place East Hampshire in the northern housing sub-area and the Paper which splits the district 80:20 north and south east. The Paper should make it clear why the change was required and how it will work - what are the implications for the monitoring of housing land supply in the District? A plan showing the boundaries of the three sub-areas would be useful so it would be possible to judge how realistic the 80:20 split is.

See above.

Yes

Respondent ref

Nature of comment

Response by Strategic Planning Authorities (SPAs)

Actions arising

4

Note that overall supply is now only marginally in excess of current RPG requirements, in marked contrast to the previous Paper.

Noted. The 2003 Paper is considered to more accurately reflect supply.

16

Table 5 should show the breakdown between greenfield and brownfield land by district and address the issue as to when greenfield sites will be available for development.

It should be possible to provide some of this information in the next Paper.

Yes

8, 15, 16

Explanation as to why Table 6 forecasts in 2003/4 onwards for dwellings completions are significantly increased over those in the 2002 Paper. Failure to acknowledge the falling returns from this source.

This is partly due to slippage from sites expected to be built in 2001-02 but were not, and partly due to more sites coming through the pipeline. Decline in supply is acknowledged from 2003/04 onwards.

15, 16

No breakdown, per local planning authority, of the allocation of RPG housing over and above those allocated using Structure Plan figures. The report provides no guidance on how any potential polarisation of dwellings may be managed and avoided, or how the difference between baseline requirement in the Structure Plan and that of RPG would be allocated (e.g. in connection with the disparities of growth between the three sub-areas).

To disaggregate the RPG figure down to individual district level would require an alteration to the Structure Plan. The SPAs have instead decided to use the Policy H4 mechanism to reconcile the difference between the Structure Plan baseline and RPG (see. for instance, Supplementary Planning Guidance `Implementing Policy H4' (June 2001).

18, 24

The estimate of housing supply lumps together potential development sites at various stages in the process. In terms of the certainty that these sites offer, they run the spectrum from having full planning permission to being allocated in a draft local plan. It may be helpful to account for each component of the supply for each district. This would enable an assessment to be made of the relative risk of sites coming forward. It would also allow those with detailed knowledge of the housing market in Hampshire to comment.

The county-wide supply of 34,115 dwellings as at April 2002 comprised :

Dwellings with full permission - 32%

Dwellings with outline permission - 18%

Allocated in adopted or draft local plan - 50%

It should be possible to provide this updated information in the next Paper.

Yes

1, 11, 13, 14, 15, 18, 20, 22

Not all committed and large sites will be built out by 2011 - over optimistic. As such it is contrary to PPG3 as it does not provide a discount rate for non implementation. There is a high degree of uncertainty over this source of supply e.g. not all allocations will be carried forward to adopted plans, greenfield directive, ownership issues etc. The Paper should look in more detail at this.

Over the next few years full local plan coverage will be achieved and give some degree of certainty over where development is to proceed. Some current sites may be lost through the adoption process but their dwellings will need to be replaced by alternative sources of supply. Allocated sites identified will either have planning permission or be otherwise suitable for development. The main reasons why these sites may not be developed by 2011 are likely to be because of decisions made by landowners and developers. The emerging regional strategy and LDFs will be required to identify further land for the period post 2011. It seems reasonable to assume that some of this could be brought forward under the `PMM' approach to fill any potential slippage from current supply at the back end of the current plan period.

1, 8, 13, 20

The Paper assumes that every small site currently committed will be completed. This does not happen and a significant non-implementation discount is appropriate. The yield should be based on past completions not permissions. To assume a continuous supply from this source is unrealistic as source is finite.

Noted. The supply figures are comparable with past completion rates. There is no evidence of supply from this source declining and could actually increase as more urban capacity small sites are developed.

7, 16, 19, 20

The release of greenfield sites and their implementation is being delayed by the Greenfield Direction. The Paper does not take this into account. The SPAs should release more greenfields to make good those greenfield sites that have not been approved through the application of the Directive.

If greenfield sites are not being brought forward as a consequence of the Greenfield Directive, it suggests that the argument for their release have not been won at site level - i.e. Inspectors or the Government do not think their release can be justified at the present time under PMM. The release of greenfield reserve sites as substitutes are also likely to be delayed or blocked by the Direction for the same reason.

19

Re: paragraph 8.4 (substitution of greenfield with brownfield sites). Fareham is in the process of delaying the release of greenfield sites because alternative sources of supply are capable of delivering its baseline. These dwelling should not be counted as part of the supply. A similar approach will be taken by all districts when deciding whether to release their greenfield sites. Therefore, unless the additional regional guidance requirement is distributed between the districts, there is no basis for the release of greenfield sites above the baseline figure for any district. All of this supply should, therefore be discounted from the counties monitoring report.

The Monitoring Paper 2003 drew attention to the possibility that the development of some allocated greenfield sites may be delayed due to the availability of brownfield alternatives. On the other hand, development on previously developed land may not come forward as fast as currently expected and a `PMM' approach to land supply within a District (as distinct from the Structure Plan's reserve site approach to PMM) may conclude that it is necessary to bring forward greenfield alternatives to maintain building rates throughout the period of the plan. Basingstoke has recently reached this conclusion. If the sites referred to in the comment were formally identified by Fareham as contributing towards its Structure Plan H4 reserve provision they would not be counted as part of overall supply.

24

The performance of large sites was over estimated last year. As a further refinement of the monitoring arrangements, would it possible to monitor the progress of large sites to ensure that they remain on course to deliver the assumed housing? For example, quarterly reports highlighting the latest planning permission and starts on site.

Current staff resources do not permit an increase in the frequency of monitoring starts and completions. It is also not clear what benefits would arise from increased frequency of monitoring. A more productive use of resources would be to undertake detailed investigation as to why particular sites have not delivered the numbers anticipated in the forecast. The reasons will help refine the art of forecasting and hopefully improve their accuracy.

20

Concern that small sites are double counted in the Paper.

Every effort was made to avoid double counting. The anticipated annual contribution 2002- 2011 from small sites is very similar to that actually built 1996 - 2002.

29

Disagree with the concept of discounting into forecasts of large site housing completions (para 6.2 and 7.3) as it is contrary to the `PMM' approach. There is no need to over allocate to meet the baseline requirement.

The discount applied in the Paper relate to the phasing of completions and is being applied in recognition that the cumulative total of previous individual site forecasts have been consistently over-optimistic. The discounting does not affect the overall baseline requirement.

Respondent ref

Nature of comment

Response by Strategic Planning Authorities

Actions arising

1, 2, 7, 14, 15, 18, 20, 22, 29

Many Urban Capacity Studies are seriously flawed when set against the advice set out in `Tapping the Potential'. The figures are wildly optimistic and unreliable. They should be subject to independent scrutiny. The Paper must include past rates of windfall development to act as a cross check on the excessive optimism. Until done it is more realistic to rely on past windfall rates. The Paper should have provided more detail on the UCS assessments.

Past rates are not a clear guide to likely future contribution from urban capacity sites. However, `Tapping the Potential' states that one way of testing the validity of urban capacity studies is to compare the predicted annual yield with the yield actually achieved in recent years. Between 1996 and 2002 an average of 2,523 dwellings p.a. came from large brownfield windfall sites and small sites. The Paper estimates that that 2,546 p.a. could be expected to come from this source 2002 - 2011. This suggests that the assumed contribution from windfalls and small sites is realistic.

7, 8, 22

Further information should be provided in the Paper on the source of data used to arrive at its net contribution from this source will not continue to be a negative or negligible amount.

The negative contribution from urban capacity sites in the first year relate to the timing of development - not whether sites will be developed. It takes longer for urban capacity sites to make a net contribution to supply as they often involve demolition of existing dwellings prior to re-development.

7, 8

Do not accept that information from the National Land Use Database published in 2001 should be used and included in the housing figures. Until the UCS are reviewed and all county districts make NULD returns, the estimate of housing supply from previously developed land, derelict land and buildings and land occupied by vacant buildings should be assumed to be nil dwellings.

The NLUD figures referred to in the Paper are not additional to supply identified in Urban Capacity Studies, but form part of it. The figures are illustrative. To include it separately would inevitably lead to double counting.

7

Table 8 should include a table of completions for each district on windfall sites on an annual basis for the period 2001/2 to 2010/11.

This is a good idea. However, it is not presently done by districts and would be hard for SPAs to do without additional resources.

Yes

19

Why do we still have to make an allowance for large windfalls when so much is made of the urban capacity studies?

Urban capacity sites represent potential supply at the date the study was undertaken. There will inevitably be additional sites coming forward that could be suitable for residential development that were unforeseen at the time of the study (e.g. sites in existing use, but subsequently declared surplus or a unexpected demolition of a building due to fire).

20

It would be helpful if the SPAs produced the assessment of district capacity as a separate document in order that everyone can be clear how the assessment ranked factors such as consultation, physical site characteristics and ownership factors.

There is merit in discussing this further with the districts.

Yes

21

The next Paper should compare the expected annual urban capacity yield for each district/UA with the windfall rates based on the data since 1996. This will allow not only the scope of the studies to be assessed but also their realism, although there are clearly reasons (of which increased density and policy changes are only the two most obvious) as to why one might expect future urban windfall/small site yields to increase over past yields.

Noted. It should be possible to produce this information for the next Paper.

20

How were the figures, in particular the 3,000 dwellings reduction arrived at?

See 8.5 of Paper. The reduction in dwellings was largely due to the changes in the assumed contribution from small sites.

7, 8, 13, 16, 18, 20, 22

The Paper simply accepts that the UCS are robust without justification. In the absence of such evidence the `precautionary principle' should be applied and windfall and UCS estimates heavily discounted. The figures should be independently assessed. At the very least the SPAs assessment must be subject to public scrutiny.

The methodology is considered to be robust. Levels of discounts now generally comply with `Tapping the Potential'. Specific challenges to the methodology and figures should be done on an individual district basis though, for instance, Local Plan Inquires.

20

The Paper should include details of past rates of windfall development (using a PPG3 compliant definition of windfalls) which came forward in the period 1996 -2001.

The next Paper will include this information. During the period 1996 - 2002 brownfield windfall (large sites) delivered 1,514 dwellings p.a. This is slightly above the 1,449 p.a. the Paper assumes from this source from 2002 - 2011. The contribution from all small sites between 1996 - 2002 was 1,184 p.a.(85% of which were brownfield). The Paper assumes 1,095 dwellings p.a. 2002 - 2011 from small sites. For both sources of supply it is clear that, based on past rates of development, the Paper is being cautious in the anticipated supply from windfalls and small sites.

Yes

5

The assumed capacity and phasing of development of the sites identified in urban capacity studies is considered to be more robust than previous forecasts

Noted.

9, 22

Urban Capacity sites have come forward faster than expected and are unlikely to contribute significantly to housing completions in latter part of the Structure Plan period. Urban capacity is forecast to increase dramatically whereas logic would suggest it should reduce as sites are used up.

Disagree. Urban Capacity sites have yet to really come into play. The comment is at variance to most other respondents who argue that UC sites are taking too long to come forward.

21, 25

How will the SPAs deal with the excess capacity (over the Structure Plan housing target) that evidently exists in Southampton and probably now also exists in Rushmoor? PPG3 para 6 states that in these circumstances the strategic authorities should work together to focus new housing development in areas where urban capacity exists rather than developing greenfield sites. When this redistribution exercise is eventually carried out it will clearly have an effect on the district distributions shown in tables 2,7, and 8.

All LPAs are required to deliver their Structure Plan baseline requirement. Any excess capacity is already included in the figures shown in the H4 Monitoring Paper and is being counted towards meeting Hampshire's RPG figure - it will not be assigned to offset the baseline requirement in a neighbouring authority.

25

Para 152 of the Transport, Local Government and the Regions Select Committee's report on empty homes said `local authorities must take account of the brownfield capacity elsewhere in the sub-region. We recommend that when the Government Offices for the Regions review local authority development plans and HIP returns, they should require local authorities to provide evidence that full account has been taken of housing supply in other authorities in the sub-region'. Thus there is a need for all three strategic authorities to look at their total urban capacity before triggering the release of any reserve `greenfield' sites so that reduced urban capacity in one authority is balanced by excess in another.

See above. The contribution from urban capacity is an integral component of calculating overall supply in the County and would be a factor in determining whether to release any reserve provision. However, Hampshire comprises more than one housing market area and it may not be appropriate to expect a surplus of brownfield land in one part of the County to meet the housing needs of another.

30

Request that the County continue to monitor the urban capacity studies of each district.

The SPAs recognise that there is a need to develop further their understanding of the potential contribution from this source of supply.

31

Attention is drawn to the Regional Assembly's forthcoming good practice advice on urban capacity studies.

Noted and welcomed. This will provide a further check on the quality and robustness of such studies.

Yes

Respondent ref

Nature of comment

Response by Strategic Planning Authorities

Actions arising

1, 4, 12, 14, 18, 19

Concur with HBF arguments on Eastleigh MDA. Eastleigh now planning to release 1,000 dwellings on greenfield land in an un-co-ordinated manner. The identification of the MDA was intended to avoid this piecemeal and unsatisfactory approach to designating land for housing. The Action Point on MDAs is a wholly inadequate response to the Eastleigh MDA. Concern that others with MDA requirements may not fulfil their obligations because of this.

The Second Review of the Eastleigh Borough Local Plan is shortly to be published and objections will be raised where the Plan is considered to be contrary to the Structure Plan.

12

The supply figures should not be balanced up in a way that removes pressure on Eastleigh to meet its housing requirements.

See above. Eastleigh is still required to meet both its baseline and reserve provision in full.

6

Factual update on status of West of Waterlooville MDA - boundary refined (to be identified in Revised Winchester Deposit Local Plan to be published in May 2003). Discussions on-going with Planning Inspectorate to hear objections on MDA in advance of remainder of Inquiry.

Noted. The comment demonstrates that LPAs are taking action to implement MDA proposals.

30

Test Valley Borough Council is in the process of preparing development briefs for the Andover MDA alongside local plan work. This should help minimise the period between local plan adoption and planning approval.

Noted.

15

Even with a start in 2005/06 there is a real possibility that our clients will build out entirely by 2011 the full MDA allocation in Andover put forward in the TV LP Deposit Draft, due to efficiencies and modern practice allowing for faster completion rates.

Noted. The SPAs will be looking for further information to support this claim when preparing the next Monitoring Paper.

Yes

7, 15, 18, 19, 22, 29

Continued failure to adequately promote the implementation of the MDAs within the County. Due to plan preparation and long lead in times it is reasonable to anticipate that the MDA source of housing supply will not provide any dwellings until 2007/08. Paper should reflect this and not assume contributions from 2006. Little, if any progress has been made since the 2002 Monitoring Paper.

Noted. This view is contrary to those above. Steady progress is being made on the three of the MDAs.

5

The assumed phasing of development of the Major Development Areas is considered to be more realistic than previous forecasts

Noted.

7

The Paper incorrectly presumes that the MDAs, subject to current Draft Deposit Local Plans will be confirmed by Local Plan Inspectors. They may not be if better alternatives are put forward.

Noted. The Paper is based on the best information currently available.

7, 8

It is unlikely that there will be completions on MDA sites in the first year, as assumed in the Paper.

Noted. Some large sites in the past have shown completions in the first year. There is still the prospect that the MDAs can be planned to deliver dwellings in the first year.

24, 29

I understood that each district is committed to meeting its own baseline. It is not clear how the apparent shortfall in MDA supply will be dealt with, and whether the district will be required to identify alternative provision. What measures are envisaged to facilitate the development of MDAs to bring about early implementation?

Each district must plan to meet its own baseline requirement. By highlighting the prospect that the MDAs may not be fully built out by 2011, the Paper serves as a `wake up call' to relevant LPAs and developers. There is still time to reduce the likelihood of this happening by speeding up planning and development processes (see comments elsewhere in the section).

27

MDAs for Hampshire were decided upon before RPG9 and PPG3 were published - the thrust of current planning policy is to use brownfield land, promote urban renaissance and minimise the use of countryside. By requiring extensive infrastructure and services they are wasteful of greenfield land and concentrate traffic in one area generating enormous congestion.

Disagree. Government recognises that nationally around 40% of all new development will have to be accommodate on greenfield land. MDAs can deliver more sustainable development objectives than other alternative forms of greenfield development.

29

Tables 10 and 11 are confusing in that the Basingstoke MDA has been included in the identified large site row rather than within the MDA figure.

The Basingstoke MDA contribution is shown in the identified large site row because the sites within it meet the criteria for inclusion under this heading.

Respondent ref

Nature of comment

Response by Strategic Planning Authorities

Actions arising

3.

Alarmed at prospect of UCS contributions replacing greenfield allocations - urge caution against such a move. Greenfield supply makes up an important component of supply.

Noted. The approach accords with Governments policy to safeguard greenfield supply.

6

Some ambiguity caused by the term "continuity of supply" (para 8.1, page 16). Suggest replacing word with "the programming"

Agreed. Will be used in next Paper.

Yes

23

Based on recent trends for planning permission is seems unlikely that the forecast for 2002-03 will be met.

Noted. An analysis of actual figures compared with the forecast will be undertaken as a means of improving future forecasts.

Yes

21

Unhappy with the assumption made in section 8.1 et seq, that a future shortfall in housing supply (compared with projections should lead to the release of reserve provision "to remedy the shortfall". A shortfall in supply can occur for many reasons other than a shortage of sites (e.g. shortage of construction workers, falling market demand). In these circumstances releasing reserve sites would not have any effect on the rate of supply of houses.

The decision as to whether to release any of the reserve is primarily dependent on whether the available future supply meets Structure Plan or RPG requirements. As the respondent states, they may be many reasons why the available supply is not then translated into dwellings.

7, 22

The Paper should include a detailed schedule for each district of the large sites accounted for in Table A. Unable to comment on Table 7 without schedule of sites, which presumably will be published in the next Housing Land Supply document. It is suggested that in future years these be published together to enable more informed representations to be made on the Paper.

The County Council will endeavour to publish both the Monitoring Paper and the `Housing Land Supply in Hampshire' documents together in future.

Yes

22

Para 9.2 - it should be noted that consents include those that are only outline only and should not be regarded as immediately implementable.

Agreed. The next Paper will present this information for both full and outline consents.

Yes

7

The Paper takes a strategic view of supply and does not consider the need to release the reserve in individual districts to meet local need.

This is correct.

8

Too much reliance on unidentified and unallocated sites to meet RPG.

Noted. The Paper showed that most new identified supply 2001-02 came from urban sources - much of which was previously unidentified. Subsequent monitoring will show whether this trend is continuing.

8

There is insufficient information about the various sources of supply to judge the realism of the forecasts given that the planning authorities have very little direct influence over the rate at which individual sites will be developed.

Noted. The current Paper is step in right direction and the next Paper will include a broader range of information to base the forecasts on.

8

Suggest that the forecasts be expressed as a range of outcomes rather than single point forecasts.

Noted. Neither the Structure Plan or RPG provide a range for housing provision and the use of a range for forecasting purposes may serve to complicate and confuse matters.

8

Should aim to maintain a five year supply of sites with planning consent rather than three year which is insufficiently robust as it does not allow for the lead times to bring large sites forward and achieve completions.

Noted. This is an unrealistic request given present levels of consents and probably unnecessary given the `plan monitor and manage' approach to housing land supply.

14

The discount in respect of the non-implementation of planning permission is welcomed but this should be a minimum of 10%.

The current 7% was based on analysis of the accuracy of previous forecasts. The accuracy of the 2002- 2003 forecast may necessitate a review of this percentage.

12, 14

Table 14 should be prepared on the same basis as Table 2 and 3 and also reflect sub areas (e.g. split in Test Valley district).

This will be considered for inclusion in the next Paper

Yes

24

The Paper does not appear to set out the assumptions used in reaching the forecast completion rates. Paragraph 34 of PPG3 advises that the development process should not be prejudiced by unreal expectations of the developability of particular sites nor by planning authorities seeking to prioritise development sites in an arbitrary manner. It is possible that the Paper will be subject to independent testing, through local plan and call-in/appeal inquiries. It is certainly the case that individual district figures will be subject to scrutiny. The SPAs should keep under review the conclusions of these inquiries and decisions and assess their impact on the conclusions in the paper.

The forecast in Table 14 is based on a more detailed breakdown set out in Table 11. The assumptions are set out in paragraphs 8.2 - 8.4. The Paper is not concerned with the merits of individual sites but the totality of supply. However, five year phasing on identified large sites is derived from the sum of individual sites based on information from the County Councils annual Housing Land Supply in Hampshire document. This is already a published document and is often referred to when testing land supply within individual districts. The outcome of planning inquiries and appeals are taken into account when reviewing supply sites and figures.

24, 31

GOSE and the Regional Assembly will continue to monitor progress on the supply of housing for early signs that completions are increasing to the levels necessary to achieve the aggregated RPG rate over the whole five year period 2001-2006. We will expect local planning authorities to take appropriate action if the housing supply continues to fall short of the RPG9 requirement.

Noted.

Respondent ref

Nature of comment

Response by Strategic Planning Authorities

Actions arising

1, 2, 3, 7, 10, 11, 13, 16, 18, 20, 22

By not releasing the reserve now the Paper ignores its own findings, those of the HCC House Completions Study and is contrary to PMM and good planning. It has followed a `predict and provide' methodology and not PMM. Need to act now rather than `wait and see' as stated in Supplementary Planning Guidance.

Structure Plan Policy H4 states that the reserve will only be released when there is a `compelling justification to do so'. The Paper has shown that the estimated supply only slightly exceeds requirements - the justification is not therefore readily apparent. It is considered that the Paper represent a robust appraisal of supply at the current time. However, there is no room for complacency and LPAs must do more to achieve their Structure Plan baseline figures as well as acting on the points listed on page 22 of the Paper.

2, 3, 10, 20

If JAP do not release sites GOSE should consider intervening - request to this effect.

Noted. See above.

5, 27, 29, 31

Broadly concur with the overall conclusion of the report .

Noted.

16

If previously developed sites fail to yield the amount of housing that is currently predicted, should greenfield sites continue to be held back, or should they be released to meet the obvious shortfall in supply? The SPAs must drive forward the early release of identified greenfield sites in local plans.

PMM would require that phased greenfield sites are brought forward to fill any gap from other sources of supply. In the first instance these should be sites that form part of the baseline supply and not the reserve. LPAs need to manage their overall land supply and bring forward greenfield allocations when and where justified. The recent actions of Basingstoke Borough Council is an example of this happening in the County.

1, 7, 20

The document fails to assess the monitoring indicators with sufficient rigour to justify the conclusion that there is no need to release any of the reserve sites. The Paper makes a number of generalised and unsubstantiated assumptions and glosses over the key issues.

Noted. The Paper is considered to represent a fair assessment of supply at the present time. Refinements and improvements to the monitoring process will be undertaken for the next Paper.

23

While the Paper expresses confidence that the lag in construction in recent years will be made up in future the available information does not lead us to agree. We conclude that there is reason to doubt the ability of the industry (even assuming its willingness) to deliver the targets that have been set and that this will show itself in an increasing failure to provide affordable housing on the scale required. We would like to see these points addressed in the final version of the Paper.

Noted. The Paper is primarily concerned with ensuring that sufficient dwellings can be built to meet Structure Plan and RPG requirements. It is for the development industry to convert that supply into houses.

17

Caution should be exercised in making a judgement to release reserve housing provision based on a forecasted shortfall in a single year as it could arise from transient conditions

Noted. The release of any reserve will require a compelling justification.

17, 21

Any shortfall in annual housing provision should prompt an enquiry into its reasons and relationship to permissions. Before releasing greenfield sites other measures should be considered e.g. greater efforts to use brownfield and other sources of supply (such as use of CPOs where a landowner is reluctant to develop an appropriate brownfield site).

Noted. The decision to release reserve greenfield sites is dependent on an assessment of overall supply, not just those with planning permission. Local planning authorities should be seeking to maximise the contribution from brownfield sites as part of their overall approach to PMM.

17

Any action to fill a shortfall in housing provision should have regard to considerations relating to infrastructure capacity to absorb any further development

Noted. Identified reserve sites should be free of development constraints.

8

General support for `action points for LPAs but seek clarification as to whether any specific innovations to enable LPAs to work with developers to remove impediments are envisaged.

Examples could include preparing development briefs; use of CPOs (e.g. SEEDA brownfield landbank initiative), undertaking further work on Urban Capacity sites to test marketability & infrastructure availability.

13

Need sensible management measures to underpin the PMM approach taken.

Agreed.

3, 14

The Paper's conclusions should have highlighted which districts have yet to identify their reserve. Future Papers should specifically identify those authorities that are not responding adequately to housing supply targets and what action is being taken to rectify the position.

Agreed.

Yes

16

The Paper does not apply the necessary flexibility in policy application to achieve the actions listed in the completions study.

Noted.

14, 15, 16

Other indicators e.g. house prices, market conditions, trends should be used to present a realistic assessment of the need to trigger the reserve. It should not just be based consideration on statistical analysis.

The process set out in Policy H4 and the SPG `Implementing Policy H4' must be followed. The Paper considers whether a release is required. The indicators referred to are more relevant when considering where to release the reserve.

9, 14

Although no release proposed this time it is probable that they will be - early identification and planning for these should be undertaken as a priority.

Noted. It is not clear that the reserve will be required but LPAs should plan to identify sites as required by the Structure Plan. Consideration as to where to release reserve provision may alter over time and should only be determined once a need has been established.

4

The margin for error for supply against RPG is too tight, especially as the forecasts have proved to be unreliable in the past.

Noted. The 2004 Paper will include a review of the assumptions upon which the current Paper is based.

Yes

4

SPAs should ensure that the baseline housing provision is fully and properly planned as a priority rather than to release reserve sites as an alternative.

Agreed. If all LPAs were meeting their Structure Plan baseline housing figure the prospect of having to release the reserve would be significantly reduced.

4

SPAs should amplify their objections to Eastleigh land supply and ensure compliance with Structure Plan requirements over provision of MDA or at least demonstrate that the alternatives are more sustainable patterns of development.

Noted. The SPAs will be considering the Second Review of the Eastleigh Borough Local Plan in due course.

5

Progress on local plans and actions recommended in the Hampshire House Completions Study should increase completions in future years and ensure that the Structure Plan and RPG targets are met

Noted.

6, 29

Welcome paragraph 9.8 reference to JAP not taking the existence of reserve provision into account when considering where to release reserve. There is, however, a need for a more detailed explanation on how the mechanism of releasing reserve sites will be applied to authorities who have or have not decided to identify the reserve. How does the mechanism work within the context of the 3 geographic sub-areas?

Noted. The SPAs will be considering the detailed mechanism for release in the forthcoming year.

Yes

27

The Paper should state that JAP has the power to release the reserve provision of x number of houses in an MDA in a specific district.

Although JAP can specify the number of dwellings required, the nature of MDA development is such that it may not be desirable to allow only part of an MDA to proceed. For instance, where it might threaten development and social cohesion and the viability of supporting community and other facilities.

27

The strategic and district authorities should work in equal partnership to determine acceptable siting and distribution of the reserve provision in the district agreed by JAP.

Although the Structure Plan provides strategic guidance it is for districts to determine specific siting issues.

27

If named as actual sites rather than `reserve provision' vast areas of Hampshire become blighted because they are required to be put into current local Plans yet may not be need in this plan period.

The identification of reserve sites in local plans brings the prospect of development to the attention of the wider community and individuals to take into account when making investment and locational choices.

27

The Paper should be amended to comply with PPG 12 para 6.24 (planned provisions should be realistic and likely to be implemented during the period of the plan). Naming the reserve sites will lead to applications and challenges - retaining their countryside designation will accelerate baseline provision.

The Paper (para 9.7) gives four reasons why all or some of the reserve may be required by 2011. Any development proposal has its champions and opponents and the identification of reserve sites in local plans ensures that the principal of development has been agreed so that they could be brought forward for development at an early stage, if required.

21, 25, 27

The requirement (para 9.8) for LPAs to continue to identify the full reserve should be dropped (i) PPG3 para 34 does not require LPAs to identify housing provision more than 5 years ahead (ii) in all probability some, if not most of the reserve will not be needed by 2011 in which case they will be in breach of PPG 12, para 6.24 (avoidance of blight) (iii) The statement that the SPAs will release the reserve irrespective of its identification implies that the need for prior identification is apparently redundant.

PPG para 34 is often misquoted, as here. In fact, it requires LPAs to identify land for at least 5 years ahead. GOSE has confirmed that the Structure Plan's policies are PPG3 compliant.

5, 26

Strong support for close monitoring and managing of housebuilding within Hampshire, including the introduction of local housing targets to enable early identification of potential shortfalls in supply and appropriate action to be taken where necessary.

Noted. Some authorities (e.g. Basingstoke) are now developing this type of approach.

27

We should not be naming sites for the hypothetical possibility that the numbers required by Government may change, if and when RPG is revised, may change.

Disagree. The current RPG clearly raises the expectation that house building rates post 2006 will rise. The planning authorities are planning for that possibility.

16, 18, 24, 27

The Paper should acknowledge that, if the MDAs are not to be built out by 2011 it follows that reserve component of MDA will not be available until after this date. For Policy H4 to operate successfully the Paper should offer some certainty that the reserve, if triggered, is capable of being delivered.

It is possible that some MDA reserve provision could be built before an MDA is finished. It depends upon the configuration of the development and detailed factors such as access provision and infrastructure availability. These are still being finalised and will be considered further in the next Paper. The SPAs expect Eastleigh Borough to plan in full to meet its reserve provision, irregardless of whether its MDA is developed or not..

Yes

26

The strategic planning authorities should urge the Hampshire districts to take all reasonable steps to bring forward as rapidly as possible the commitments, brownfield sites and allocations that make up their projected supply and report back significant delays or difficulties with sites.

SEERA, GOSE and the SPAs are all looking to the LPAs to bring forward the housing supply in their area. JAP has requested information from the LPAs on housing provision in their areas (see concurrent report on Agenda).

27, 29

We view with alarm the number of LPAs that have failed to identify the reserve provision. It would be inequitable if those authorities that had identified the reserve were disadvantaged by their compliance with the Structure Plan. Support the requirement that LPAs should continue to identify the full reserve provision - the SPAs must take a hard line when such provision is not made. The Council is concerned that should reserve sites be required in the next two years there are no `reserve sites' in any adopted Plan.

The SPAs are not certifying local plans that do not make the full reserve provision and are objecting to the lack of identification where necessary.

The likelihood of having to release any reserve in the immediate future would be significantly reduced if all planning authorities were delivering their baseline housing requirement.

JAP should recommend that the SPAs confirm that the absence of reserve provision will not have a bearing on considerations as to where a release should be made, if required.

Yes

5

The Council is concerned that the reserve provision is not identified to rectify shortfalls in completions against baseline requirements in other districts, or in advance of additional urban capacity (over and above baseline) identified within south Hampshire.

All LPAs are required to meet their baseline requirements. Additional supply from urban capacity is being counted towards the County RPG figure rather than the sub-areas.

Respondent ref

Nature of comment

Response by Strategic Planning Authorities

Actions arising

18

The adopted Structure Plan is effectively out-of-date as a consequence of a shifting RPG9 requirement and a development strategy that is being ignored by the various districts in the preparation of their local plans. If the Structure Plan is to continue to influence the location of development and remain relevant, it is essential that it is subject to review as a matter of urgency

The Structure Plan's housing strategy was designed to be resilient to a variety of RPG figures. With only a few exceptions, development is proceeding in line with the Plan. This was demonstrated in the Structure Plan Monitoring Report 2002.

1, 20, 22, 30

Reject the inclusion of MOD properties for the simple reason that MOD personnel do not form part of the household projection information which resulted in the housing requirement in the first place. They should only be counted when they are surplus to MOD requirements and are genuinely available to the general population on the open housing market. Danger of `double counting' such properties. Should revert back to pre 2001 approach.

SEERA has advised that where this question has arisen, the way it has been dealt with varies:

West Berkshire - MOD housing is included as part of the housing stock estimate.

Chiltern and South Bucks - Issue has not arisen, but if it did MOD housing would be treated as part of the overall dwelling supply in line with the HFR form.

West Sussex, Wycombe - MOD housing has been/is treated as part of the overall dwelling supply.

Kent - MOD housing is not treated as part of the overall dwelling supply unless sold for redevelopment and where a planning permission is involved

Oxfordshire: As Kent - however, this may be reviewed.

SEERA intends to consider this issue further when it next collects data on housing completions and land supply.

Until the Regional Assembly has determined how it wishes to collect housing data the Hampshire Housing Land Supply Monitoring Information should continue to treat MoD housing as part of the overall dwellings supply.

12, 18

Future Papers should consider house types and tenure rather than identifying `dwelling' demand and supply generically. Concern that present supply over provides for upper range apartments and does not cater for family housing. This issue should be considered against 2001 census data.

An important issue but outside the remit of the Paper. The Structure Plan requires local plans to plan for a range of house types and tenure. The Census will be analysed to inform issue for future plans. However, the Policy H4 Monitoring Paper is not the place for this to be considered.

23

As future Papers will be published approximately a year after the end-date of the period covered, it would be useful to include preliminary estimates of key statistics as far into the next year as possible.

The Supplementary Planning Guidance (SPG) on Policy H4 envisages each year's Paper being published in November, 8 months after the period to which the data relates. The SPAs do not have the resources to also produce interim statistics.

23

Disappointed that our request for more information on affordable housing provision has not been met. The continued shortfall in overall dwellings completions compared with RPG is having a direct effect on the numbers of those dwellings that are `affordable'.

Data on affordable housing not presented in the Paper because the SPG states that the need for affordable housing will not influence decisions on whether to release the reserve provision. Such information is however, included in the Structure Plan Monitoring Report 2002.

16

The ONS figures indicate an increase in housing numbers in Hampshire between 1996 and 2011 from 660,000 to 775,000, an increase of 115,000 - far more than is presently planned for.

Noted but not relevant to the Paper or decisions on whether to release any of the reserve provision.

17

Detailed comments on proposed reserve Major Development Area - Winchester North

Not relevant in the context of the Policy H4 Monitoring Paper.