APPENDIX 3

Supporting the delivery of new housing

Hampshire County Council's response to proposed Changes to PPG3 - Supporting the delivery of new housing are as follows.

Question 1

Will the proposed change improve the delivery of new housing in your area? Response

Yes, it is likely to result in the delivery of some additional housing in Hampshire but this `quick fix' could cause problems in the future as it is likely to result in the loss of the variety and range of employment sites over the long term. It may also result in more pressure being placed on the use of greenfields for industrial use in the medium to long term.

Question 2

The proposed new paragraph 42a sets out a series of considerations for local planning authorities in their determination of planning applications for proposals described in the paragraph. Do you agree that local planning authorities in determining such planning applications should consider whether:

a) The proposal fails to reflect the policies in PPG3, particularly those relating to a site's suitability for development and the presumption that previously developed sites (or buildings for re-use or conversion) should be developed before greenfield sites?

b) The housing development would undermine the planning for housing strategy set out in RPG or the development plan where this is up-to-date, in particular if it would lead to over-provision of new housing where this will exacerbate, or lead to, low demand?

c) There is a realistic prospect of the allocation being taken up for its stated use in the plan period or that its development for housing would undermine regional and local strategies for economic development and regeneration?

Response

The proposed change is not considered an improvement. The new paragraph is not helpful and no change should be made to paragraph 42. The presumption should be that land is retained for employment purposes unless it can be demonstrated that it is no longer required and that development for housing would not undermine strategies for economic development and regeneration.

Question 3

Is the proposed change likely to be advantageous to small businesses?

Response

No. The consultation paper expresses well the potential risks to business development, especially small businesses, of adopting the proposed change in paragraphs 36 and 37 of the Partial Regulatory Impact Assessment ( Annex B). It states:

36. Where a local authority was unable to provide the defence for a site capable of defence of retention, there could be insufficient land of the right type and quality and location for business development, which could hamper economic growth. There could be particular detrimental effects on firms where it is beneficial for them to cluster in the same area as opportunities are lost to cluster to housing and mixed-use development.

37. Some sites, especially for small-scale business development and expansions, could be lost if landowners decide to seek a change of use to housing. Small businesses could potentially be squeezed out, unless policies specify mixed-use development, and where opportunities are lost for on-site expansion this could prompt potentially expensive moves to other premises.

In Hampshire the likelihood of these risks is so amplified by market conditions as to be unacceptable.

Despite a general downturn in activity in the industrial and commercial property letting market since 2001, practitioners report a continuing demand from mainly local businesses for small and medium sized accommodation. There is currently less interest in larger buildings, particularly older second hand properties. Market practitioners nevertheless believe that there is an insufficient range of choice of sites and premises which is likely to worsen as those sites currently under development reach completion. The apparent preference for new build premises can only be satisfied if there is an efficient supply of employment land released by the planning system.

There are instances of apparent market failure where allocated sites are not brought forward but this is often because of access, infrastructure and ownership considerations.

Question 4

Local authorities will need to carry out and keep up-to-date assessments of the need for land to be allocated for employment uses (and for particular types) over the plan period and a review of the suitability of particular sites. They are already expected to do this. The Partial RIA sets out circumstances where additional costs may be incurred. Are these circumstances likely to arise frequently?

Response

The need to carry out and keep up to date assessments of the need for land to be allocated will result in local planning authorities incurring additional costs on a frequent basis. The assessments will need to be reviewed more frequently than they are at present. It is considered that they would have to be reviewed more frequently than every five years (as suggested in the impact assessment) in order to be considered up-to-date assessments. The very significant difference in values of land for employment use and for housing is likely to result in land owners of land allocated for employment use making more speculative planning applications or holding land back in the hope of securing the markedly better returns from housing.