Archived decisions

RESPONDENT

REFERENCE

NATURE OF COMMENT

RESPONSE BY STRATEGIC PLANNING AUTHORITIES (SPA'S)

1, 3, 5, 13, 23, 29, 33, 38

The proposed process is the correct one and is welcomed for its clarity, transparency and detail.

Noted

9

The process is clear. Consideration needs to be given to the relative environmental constraints in each of the sub-divisions and Districts.

The environmental constraints were taken into account when allocating the reserve sites in Structure Plan policy H4. They should also be taken into account in deciding which sites to allocate for reserve provision in local plans.

36

Process meets the tests of clarity and reasonableness with the exception of the sequence described in 5.2 (ii). A second paper should be prepared for the same meeting of JAP indicating where the release should be made in the event JAP conclude contrary to officers recommendation that a release of reserve land was necessary.

Noted. It is not considered necessary to take a second report to JAP in the event that the first report recommends that no release is required.

16, 17, 18, 22, 28, 30, 32

The process is unreasonable. The factors outlined, whilst being clear, are often contradictory and unreasonable and therefore unworkable. A quick response is not possible. It is lengthy and does not take account of potential delays in the planning process. The agreed spatial strategy should be adhered to and planned through the proper process, the Structure Plan review or the forthcoming Regional Spatial Strategy, not through SPG.

SPG must not be used to avoid public scrutiny.

See comments in appendix 1 (Question1& 4)

20, 21, 25

Addendum seems to add little if anything to the original, clearly set out SPG. Purely seeks to divert attention away from the real issue, the delivery of Policy H1 structure plan housing requirement. The addendum should make clear that housing land supply must be considered within the context of the Policy H1 (94,290 dws) requirement, not just the H2 (80,290 dws) baseline requirement. Even if met, this wouldn't deliver the RPG annual housing requirement

Noted, The Addendum is intended to clarify the process so that sites can be identified as quickly as possible if a decision is made that it is necessary to make a release. See appendix 1 "Other comments"

23, 35

Many factors may change over time or conflict with each other. This is particularly the case of structure plan figures that were set before RPG figures, as the time to 2011 diminishes there will be increasing pressures for decisions to be made on the basis of progress towards RPG totals.

Noted.

28

There is no allowance for the different economic factors affecting the disparate areas of Southampton, Portsmouth and the New Forest.

A comparison of the forecast in labour demand and supply will be one of the factors considered in deciding where to make the release.

22, 37

Basis for release is in isolation from the performance of the construction industry. There should be a factor related to this performance. However, paper should also recognise that the industry can't be compelled to build.

Performance of construction industry is taken into account in forecasting how many dwellings will be built each future year in the annual monitoring paper. A release will only be made if there is a compelling justification. The addendum only clarifies the process of deciding where the release will be made.

30, 31

General lack of clarity and objective measures capable of yielding objective and transparent decisions is of great concern. As is apparent disassociation between need for housing in a particular area and the requirement to meet nebulous housing targets by whatever means. How will LDF's affect triggering mechanism?

3.2 should be removed and 3.1 made binding for the SPA's as 3.2 allows SPA's to fall back and override the process laid out in 3.1

A release will only be made if there is a compelling justification. The addendum only clarifies the process of deciding where the release will be made. LDFs will need to be in conformity with the Regional Spatial Strategy . Its housing policies are not yet known. Changes have been made to the addendum to clarify which factors are most important.

34, 35

The process should be as clear and straightforward as possible in order to reduce any subjectivity that may be involved. There could also be some drafting changes to make the process clearer and congruent with the diagram.

Noted.

RESPONDENT REFERNECE

NATURE OF COMMENT

RESPONSE BY STRATEGIC PLANNING AUTHORITIES (SPA'S)

1, 15, 29

The proposed factors appear to be broadly the right ones, they cover all the relevant issues and provide a comprehensive basis for decisions on where to release reserve sites.

Noted

38

Criteria set out in section 3 are useful but tend to favour the Northern Hampshire sub-area, where housing markets are buoyant, housing is more expensive, and there is a shortfall of labour supply in some parts.

In the past the emphasis has been on each sub-area trying to meet its own housing needs; the new criteria do not give enough emphasis to this as the starting point for all decisions.

Addendum amended to clarify that performance on completions and supply is the most important factor. See Appendix 1 Questions 2& 3

13, 23, 27

The factors are generally considered appropriate. However, 3.1 (i) should be a prerequisite of any release in any sub-division.

Only if criterion (i) is met should the other criteria come into play. Otherwise it may be argued a release is justified on the criterion of 3.1 (ii-v) alone.

See appendix 1 Question2

39

The requirements in 3.1 - 4.2 of the `Addendum' are not the most relevant. Deliverability is most important factor.

Deliverability is taken into account in deciding in which district or MDA to make the release (factor (iii)). It is also something which district councils should take into account in deciding which sites to release.

15, 22, 31, 34, 40

How would `under-performance' in 3.1 (i) be defined and measured. There are too many factors involved for it to be a reason for release of reserve. There needs to be greater sophistication in its use, or thresholds specified. It depends on the reason for under performance. Unacceptable to use county wide basis of underperformance, when particular sub-divisions may be meeting their obligations under the structure plan.

Underperformance is any shortfall in relation to the annualised Structure Plan baseline requirement for any sub area or district. Changes have been made to give some weight to each of the factors see Appendix 1 question 3.

34, 35

Under-performance should be a reason in itself for the release of reserve housing sites, not merely a factor favouring the release of such provision. But maybe a change needed here; "if any such under performance is irremediable, it could become a factor favouring that same sub division for the release of some reserve provision".

Change made to indicate that performance on completions and supply is the most important factor. See appendix1 question 3

36

Reference should be made in 3.1 (i) to the possibility of making good any performance shortfalls arising within one sub-division by the release of reserve land within the nearby part of the adjoining sub-division.

Not considered appropriate, see Appendix 1, response to Question 2

3, 25

The house price/income ratio can only be one guide; the size and nature of property has to be an equal factor in deciding what is built.

Agree that house price/ income ratio is only a guide to affordability. Limited statistics are available at a district level.

5, 6, 24, 25, 31, 32, 35

House price inflation and vacancy rates as in 3.1 ii, are poor measures. Needs careful interpretation or removing.

Vacancy rates have been deleted from the factors used and house price inflation is now one of the factors of lesser importance. See Appendix 1 Questions 2 & 3

29, 32, 36

Certain areas of the county are large and diverse areas that make it unrealistic to consider them as single housing market areas.

Analysis of this factor may be better suited to within sub-divisions. However, conversely wide scale connectivity in many areas such as the Southampton conurbation and surrounding districts puts a limit on the effectiveness of many factors.

The analysis will be at first at sub division level and then at district level . The shortcomings of analysing housing demand in this way are acknowledged, however it is considered that housing demand should be one of the factors taken into account in deciding where releases should be made. It is now proposed to make it one of the factors of lesser importance.

5, 24, 31

No correlation between dwelling supply and house prices as in 3.1 (iii). New Earnings Survey data relates to place of work not residence and is inappropriate due to insufficiently large sample size. The validity of the Local Economic Forecasting model as in 3.1 (iv) needs public demonstration. Correlation between place of work and residence is getting weaker.

This factor (3.1(iii)) looks at the affordability of housing in the area by comparing earnings with house prices. The limitations of the New Earnings Survey are acknowledged , but it is the best information available. The Structure Plan aims to minimise the need to travel in order to minimise damage to the physical and built environment. It is now proposed to make these factors of lesser importance.

25, 31, 34, 35, 36

Analysis of labour demand and supply 3.1 (iv) is an essential consideration, but must be compared to existing and proposed housing supply. It can also vary dramatically between the local and regional level and the date at which the shortfall is set to arise.

Extreme caution should be taken when evaluating this factor.

Agree that we will need to be careful when evaluating this factor. It is now proposed to make it one of the factors of lesser importance.

15

Under 3.1 (ii, iii and iv) the authorities need to consider how frequently these databases are updated and how reliable they are. The 2001 travel to work data, when released, could illuminate the situation.

It is now proposed to make it these factors of lesser importance. Agree that we need to take into account the reliability and date of the information being used.

27

None of the five criteria under paragraph 3.1 seek to assess the actual deliverability of housing within any sub-divisions, looking purely at the forecast performance in relation to the baseline.

Deliverability is a factor which needs to be considered when deciding in which district or MDA to make the release. It is not considered appropriate to consider deliverability in relation to sub-division as the Structure Plan seeks to provide locally for the needs arising within each of the sub-divisions.

25, 37

Affordability as a factor is supported, but should be based on the scale of need rather than on comparison of house price/income ratios. If affordability is a factor then a small release would have a negligible impact on house prices. This inconsistency needs to be addressed.

It is not intended that a release would have an impact on house prices. A high house price to income ratio suggests that there is a high demand for housing compared to the supply available in that area.

3

"One bedroom/two bedroom" should be part of the definition of affordable housing.

Affordable housing is required in a variety of sizes.

22, 24

The affordability factor should be dropped from paragraph 3.1. Building new homes in one sub-division because they are affordable is not the answer to meeting a housing need in another.

It is now proposed to make this one of the factors of lesser importance.

37

3.1 should recognise that some areas are meeting their targets and that position should be a factor in the consideration of the release of reserve sites to the benefit of that area rather than as a possible reason for making further allocations.

This is being taken into account. Only if a sub-division or district is underperforming would it be a factor in favouring a release in that area. Performance on completions and supply will be the most important factor. See Appendix1, Question 3.

34

Ratio used in second sentence of 3.1 (iii) is not always likely to be a relevant factor, and should not be a causative factor.

It is now proposed to make this one of the factors of lesser importance.

28

Factors in 3.1 and 4.2 are ambiguous and very difficult to understand. An informed decision cannot be made on whether release of land would be appropriate.

See response to Questions 1&3 in Appendix 1.

39

The policy requires socio-economic issues to be analysed so that the location of a release to meet the identified shortfall can be determined. Process likely to be extremely time consuming and subjective due to authorities deciding themselves on the weight to be given to such indicators if they produce contrasting conclusions.

See response to Questions 3 and 4 in Appendix 1.

24, 34

Unclear what is meant by a small release in section 3.1 (v) and "Spread" might be better than "size" in 3.1 (v) and 4.2 (ii).

A release of, for example, 500 dwellings would be considered a small release.

5, 30

Factors 3.1 (ii-iv) and 4.2 (iv) and (v) are outside the scope of policy H4 and are contrary to PPG12. They are not PPG3 sustainability criteria and are too short term for an essentially strategic decision. The release locations should be as few as possible and driven by strategic considerations, particularly the sequential approach.

It is now proposed to make these factors of lesser importance. See response to Question 3 in Appendix 1. Each district will decide which sites within their district to release unless the whole of their reserve released.

8, 9, 22, 25, 30, 31, 36, 35, 40

3.1 and 4.2 fail to recognise the importance of environmental considerations, infrastructure including employment availability, transport, already developed land and sustainability. Need factors relating to the ability of the district to cope with the release. Recommended that a further criterion be added to both 3.2 and 4.2 along the lines of; "The potential consequences of the release of the land on the environment, or environmental capacity of the sub-division or District".

These factors should have been taken into account in identifying the reserve sites in the local plan. All sites allocated should be suitable for housing development. If it is necessary, it should be possible to release all the reserve sites.

25, 35

Wherever possible the release of reserve housing sites should be within the district identified to have the shortfall/need. However, if an MDA within a district cannot come forward, alternative MDA's in other districts should be considered rather than making up any shortfall from smaller sites. The benefits of MDA's over smaller sites should be recognised and priority given to them accordingly.

See response to question 2 in Appendix 1. The Structure Plan seeks to provide locally for the needs arising within each of the sub-divisions, therefore the release of an MDA in another subdivision would not be appropriate.

7, 13, 15

Clarification set out in paragraph 4.2 (ii), regarding the Winchester City North MDA, is particularly welcomed. However, the specific factors affecting it should be summarised. However, concern that it may be inappropriate to name one specific area as an example particularly when it is not the only area in Hampshire that may fall into this category.

Winchester City (north) MDA was mentioned as it is the only MDA which does not form part of the baseline requirement. As an MDA should comprise at least 2000 dwellings it is considered that a release of only part of it would not be appropriate. It is not considered appropriate to make any further reference to the factors affecting Winchester City (north) MDA in the addendum.

10, 11

The issue of full release of the Winchester City North, Major Development Area (MDA) stated in 4.2 (ii) should not be included.

The area was selected because of its discrete nature and sustainable potential. The justifications for this are not valid. Given its un-sustainability it shouldn't be triggered merely because of its size. There are wider reasons and repercussions for not releasing it at all.

See comments above. The location of Winchester City (north) MDA is a matter for the Winchester District Local Plan Review.

22, 38

Not clear why the North Winchester reserve MDA should not be considered for release unless the whole site is needed. MDA's will take some time to complete and require considerable infrastructure investment; once development has started on site it will help bring the remainder of the MDA forward in the next plan period.

The addendum says that it would be sensible not to trigger the reserve MDA at Winchester City (north) unless the whole of it is to be released. This is because an MDA should comprise at least 2000 dwellings so that appropriate infrastructure and facilities can be provided, e.g. primary school. Agree that if the MDA was released development could continue into the next plan period.

14, 25

Recognised that the proposed MDA's will not be complete by 2011. It follows that any reserve release cannot relate to an MDA as it would not produce additional completions prior to 2011.

This may be true in some cases, but in others it would be possible to build on the baseline and reserve MDA sites at the same time if the developer wished to do so.

12, 13, 17, 18, 32

Paragraph 4 raises the prospect of conflict with District Council authorities. 4.2 should make it clear that decisions taken in response to those criteria cannot be allowed to override any sequence of priorities contained in a District Local Plan. Any reserve housing should match areas of deficit. Releasing reserve provision in one district to meet shortfalls in the wider sub-division should only be done where there is also a shortfall of provision in the District concerned.

See response to question 2 and Other Comments in Appendix 1.

The factors in 4.2 will only be used to determine in which district or MDA to make the release. If a decision is made to release a certain amount of the reserve in a particular district, it will then be up to the district to decide which sites to release (unless all the reserve is to be released).

5, 14, 19, 20, 21

The criteria seems sensible. Main concern is the time lag between deciding any releases are required and actually making the release. Addendum fails to properly consider the implications of the delay. This will lead to decisions made on appeal, a lengthy process that affects the ability of the District to meet the identified shortfall. Lead in times need to be established and agreed before a release is likely, draft fails to acknowledge this. Site ownership is the key delay: CPO should be used if necessary.

See response to Question 4 and Other Comments in Appendix 1.

16, 17, 23, 32

4.2 (iii) and many other criteria are too restrictive and imply that long term vision will be sacrificed to meet short term needs. They imply that reserve sites may not be released where it is perceived they cannot be completely released within the timeframe required. This is a possibility. Concern that infrastructure thresholds of sites may not be reached and under performance in housing provision reinforced. Need to look more widely to create a more sustainable pattern of development in Hampshire.

See response to Question 2 and 3 and Other Comments in Appendix 1.

25, 27, 39

Reference to `deliverability' in 4.2 (iii) is welcomed and thought of as fundamental. However, it must be considered in the context of overall level of house building required to be delivered within each district.

Noted

15, 19, 30

What is the relevance of 4 (iv). Is it measurable or even achievable. What point is being made and how it could in any event be anticipated.

This factor is relevant as there is no point in making a release if the housing would not be occupied on completion. A knowledge of local housing markets will be used to assess this factor. It is now proposed to make this factor of lesser importance.

19, 35

Do not disagree with factor 4 (v), so long as a high demand for affordable housing would not be overriding in comparison with areas of high private sector demand. Each would need to be acted upon.

It has been decided to give some weight to each factor. This factor is now of lesser importance.

See response to question 3 in Appendix 1.

5, 23

Under 4.2 (v), it should be made clear whether a shortage of affordable housing in one district could be used to justify its provision in another district (sub-division). Indicators are that any emerging shortfall in provision of housing will be disproportionately attributable to the affordable sector. However, every authority needs more affordable housing, so using it as a criterion raises very important issues.

It has been decided to give some weight to each factor. This factor is now of lesser importance.

See response to question 3 in Appendix 1.

37

4.2 (v) is a cause for concern, the definition of "above average" is vague and may not convey the particular circumstances of an areas housing needs.

It has been decided to give some weight to each factor. This factor is now of lesser importance. "above average" relates to a comparison with other districts in Hampshire.

40

As well as a requirement for affordable housing 4.2 (v), the criteria should relate to the actual potential to deliver further affordable housing, taking account of issues such as land ownership, availability of public subsidy to deliver affordable housing and the physical location of the reserve land relative to local areas of need.

It has been decided to give some weight to each factor. This factor is now of lesser importance. These matters are ones which the district may wish to take into account in deciding which sites to release.

30, 34

Factors in 4.2 (ii and iii) acceptable, (iv and v) unacceptable.

It has been decided to give some weight to each factor.

See response to question 3 in Appendix 1.

19, 34

Many of the factors in sections 3 and 4 relate to existing problems with causes rooted in the past. They are responses and avoid the problems arising. They do not anticipate land supply problems. It is also not clear whether they are the only ones which can be considered. More clarity needed here

See response to question 1 in Appendix 1

22

Impact of unforeseen major windfall sites must be taken into account

These will be taken into account when undertaking annual monitoring.

33

Primary consideration should be the performance of the sub-division(s) and individual districts in delivering the Structure Plan baseline requirement, unless other considerations are of significance to warrant a contrary decision.

It has been decided to give some weight to each factor.

See response to questions2 and 3 in Appendix 1.

35

Piecemeal releases on such a complicated basis, with such local variations give the development industry no certainty and in-adequate lead-in times to provide a prompt and meaningful response by way of completions

See response to other questions in Appendix 1

24

Consideration should be given to the value of reserve sites to the community as they stand today. Release first, those sites with least community value.

This addendum clarifies the process of deciding in which district or MDA to make the release. District Councils will decide the location of the reserve sites and which ones to release first within their district.

RESPONDENT REFERENCE

NATURE OF COMMENT

RESPONSE BY STRATEGIC PLANNING AUTHORITIES (SPA'S)

1, 6

Different weight should be attached to the factors, with housing supply, labour demand versus supply, vacancy rates, and housing affordability being the primary considerations.

See response to question 3 in Appendix 1

17, 18, 32

The principle factor should be the shortfall in housing in particular districts, and this should therefore be the primary consideration in releasing reserve housing land.

See response to questions 2 and 3 in Appendix 1

1, 27, 31

High weighting should be given to factors 3.1 (i) and (v), and 4.2 (i-iii). Low weighting should be given to 3.1 (ii-iv) and 4.2 (iv) and (v).

See response to question 3 in Appendix 1

23

If 3.1 (i) was a pre-requisite of any decision to make a release, no `weighting' would be needed.

See response to questions 2 and 3 in Appendix 1

35

High weighting should be given to any sub-division(s) which are under-performing in relation to baseline housing requirement. This is the only absolute measure for monitoring house building rates and should therefore be given highest possible weighting.

See response to questions 2 and 3 in Appendix 1

35

Other factors outlined in this section provide diverse methods of analysis of questionable relevance. Their diversity and complexity may impact upon their accuracy and reliability.

See response to questions 2 and 3 in Appendix 1

9, 22, 28, 34

Support the need for weighting, but further work needed to achieve consensus on what, if or how any weighting system should be applied.

See response to question 3 in Appendix 1.

40

Weighting may be desirable, but difficult to see how can be effectively applied as will change over time. Weighting will be a matter for political judgement when the decision is taken to release land.

See response to question 3 in Appendix 1.

35

Views of property professionals and house builders should be sought and given high priority.

Their views will be sought when the process is applied in practice.

RESPONDENT REFERENCE

NATURE OF COMMENT

RESPONSE BY STRATEGIC PLANNING AUTHORITIES (SPA'S)

1, 8

The proposed decision-making sequence strikes a good balance between expediency and allowing for consultation.

Noted.

5, 8, 30

Section 5 is supported.

Noted

24, 40

As the areas have been considered already through the Local Plan process, the process set out for consultation is considered to be appropriate. However there is no clearly defined timescale for the public comment period in (iv/v), this is unacceptable.

See response to question 4 in Appendix 1.

15, 17, 28, 34, 37

Sequence should not be speeded up. The time allowed does not provide for realistic and informed discussion and comment by LA's. A nominal time scale for LPA's to do what is necessary needs to be set. Neither does it give enough time for those comments to be properly assessed before formal decisions are made and action is taken. It could be speeded up but only by cutting out some participant or other, which is unacceptable. On balance, the proposed process is best.

Noted. See response to question 4 in Appendix 1.

37

The process of reviewing the case for releasing sites should be re-evaluated in terms of the length of time envisaged.

It should be possible to take less than 11 months to produce a paper on the land supply position. Eg the March 2004 JAP meeting is considering data as at April 2003. This is particularly pertinent given any recommendations are to be considered by the three SPA's.

The policy H4 monitoring paper is produced in the quickest time possible within the available resources and is published for consultation in November / December.

1, 15

The addendum is not clear in paragraph 5. It needs to be more precise about stages (iv) and (v), specifying a time for decision making.

See response to question 4 in Appendix 1.

19, 20, 25, 27, 35, 39

The process is insufficiently forward looking, far too long and too slow. Will result in uncertainty and delays in sites coming forward

See response to question 4 in Appendix 1.

18, 32

SPG introduces yet another delay in meeting the Structure Plan requirement. Once the need is established it should not be delayed further by a debate on where. Spatial Strategy is already agreed, provision should be made now so that it can be released without delay.

See response to question 4 in Appendix 1.

35, 38

There should be a mechanism for triggering the release of sites that could be implemented outside of the cycle, if a need/shortfall is identified. Release of sites appears to be a two-tier process. In order to reduce time, the process in section 5 should be combined

An annual review is considered sufficient. See response to question 4 in Appendix 1.

RESPONDENT REFERENCE

NATURE OF COMMENT

RESPONSE BY STRATEGIC PLANNING AUTHORITIES (SPA'S)

14, 22, 36

Leaving the decision of the release of the reserve to the three SPA's is too narrow. There needs to be a new forum of JAP including all the districts and SEERA who would need to be able to make a decision on the way forward. Addendum should make it clear how the process would be taken forward speedily.

It is not considered necessary to have a new forum., but some amendments have been made to the addendum in relation to this issue. The conclusion on the sub-division(s) in which the reserve should be released will be made by the strategic planning authorities representatives on the Joint Advisory Panel. The conclusion on the District(s)/MDA(s) in which the reserve should be released will be made by the strategic planning authorities representatives jointly with the representatives of the local planning authorities in that sub-division.

27

Criterion (v) under paragraph 5.2 conflicts with the statement in 4.1, that both strategic and local planning authorities would decide where a release is required. 5.2 needs to be amended accordingly.

Agree amendment required. Changes made to clarify the role of the strategic and local planning authorities. Following consultation, second report will now be considered by JAP with opportunity for each authority to put forward their response. Also see response above and to other comments in Appendix 1.

15, 23, 25, 27, 34

Neither 5.2 nor 5.5 are clear about which body does what. 5.2 involves the process by which the second report, on which JAP bases its recommendations, will have been made without the benefit of public comment. Needs to be better clarification as to whether or not public comment is to be sought. 5.5 should make clear the ways in which the structure plan authorities will exert their authority in the event of any difficulties. Also needs to be made clear whether `the strategic and local planning authorities' deciding in which district a release should be made, would include only the LPA's within that district.

Agree amendment required . See response above.

1

For additional clarification the following sentence should be added to paragraph 4.3; "Where a district falls within two sub-divisions, the release must be made within the sub-division identified in section 3 of this addendum".

This is considered to be a matter to be determined by the district rather than the strategic planning authorities.

29

Addendum should give equal status to county, unitary and district authorities in the decision making on which sub-division the releases should be made in. This will bring housing distribution in line with requirements of new Regional Spatial Strategies.

It is not considered appropriate for the districts to decide the sub- division(s) in which the releases should be made.

27

Suggested that wording of 5.4 be amended to confirm that it is not the total capacity of a site that must meet the quantum of the reserve required, but rather it is the number of dwellings that can be delivered in the period to 2011 that is required to meet the reserve release.

Understand the point being made but consider that the wording is adequate.

22

Paragraph 5.5 is unclear as it does not define what promptly means in these circumstances. Paragraph 5.6 may become redundant depending on the final form of the Planning and Compulsory Purchase Act.

No amendments are considered necessary, it is acknowledged that paragraph 5.6 may become redundant.

1, 13, 30, 32

The clarification in section 6 relating to the non-identification of reserve provision is welcomed. `Non-identification' of reserve provision is highly relevant and absolutely essential. The county must further consider this issue now and place pressure on the districts to meet their requirements.

Noted. See response to other comments in Appendix 1.

15

Paragraph 6.1 seems to say that any districts which have not identified a reserve provision will not necessarily escape land release. This should be more clearly phrased in order to avoid any confusion.

See response to other comments in Appendix 1. Do not consider that there is any confusion about this matter.

14

The current process takes no account of those factors the SPA's feel are essential in deciding where the future releases may take place, and is, in effect, a planning lottery. Favours those authorities which ignore the strategic context.

Noted.

22, 37

Paragraph 6 is unacceptable as drafted. 6.3 leaves authorities with no reserve identified to the vagaries of the appeal process. This is not an appropriate way for the strategic planning authorities to be devising policy. Its inclusion should be reconsidered. 6.2 covers the point which needs to be made ie. Where reserve sites have been identified the LPA's are in a good position

See response to other comments in Appendix 1.

32

Statements made in respect of the reserve release at section 6 are in conflict with the criteria identified at section 4.2. There are clearly time implications associated with planning process, and failure of districts to plan for provision will inevitably cause delays. The SPG assists those districts and is therefore unacceptable.

See response to other comments in Appendix 1.

14

It is bizarre in the extreme, that the strategic planning authorities seem to be endorsing planning by appeal.

Proves the point that the SPA's have lost all credibility.

See response to other comments in Appendix 1.

12

The Draft does not specifically admit that up to the present time there is no need for any release of reserve sites in the County. It is clear from the tenor and language of the Draft that this remains the position. Why some 8 years into the Plan has the requirement not diminished. This requirement can safely be reduced.

The addendum is intended to clarify a process. It is not a monitoring paper.

14

Have always argued, and not had an adequate response, that the regional guidance should be interpreted by the SPA's now in terms of district distribution. The criteria referred to are ideally suited to deciding how to distribute the regional guidance. If this approach was adopted, it would then allow local plans for each district to be considered in the proper context.

This is not a matter for the addendum to SPG on implementing policy H4. Distributing the Regional Planning Guidance housing figure for Hampshire would necessitate changing the Structure Plan policy which can only be done by a formal review of the Plan.

16, 17, 32

The Structure Plan EIP Panels' advice for a major Greenfield release are not being followed through the SPG.

The policies in the adopted Structure Plan are being implemented. It should also be noted that the EIP panel's report pre dated PPG 3.

16

Consultation with the Strategic Health Authorities (in line with PPG12, Annex C, section 4) should be specifically addressed in the text, as there are always healthcare implications when sites are released.

A good practice example is Milton Keynes where a Health and Social Care Sub-Group was created to feed into the town planning process.

Consultation will be undertaken with a wide variety of organisations including the Strategic Health Authorities. Consultation is also undertaken by the districts when they decide which sites to allocate for housing in the local plan.

19, 21

A process needs to be developed that includes those involved in the delivery process more closely including house builders, landowners and their agents, District Councils (housing and planning departments) and RSL's in order to foresee and plan for land releases. At present the addendum doesn't provide any greater comfort to the house building industry that the Hampshire SPA's have any intention of releasing any of the reserve provision, unless forced to from above

The addendum is intended to clarify a process of deciding where the release will be made. It is not a monitoring paper. The consultation process proposed is considered adequate. Policy H4 states that the strategic planning authorities will only support a release of the reserve provision if there is a compelling justification to do so.

34

Less justification for the two cities to impede or frustrate the wishes of the county, in terms of SPA's decisions, unless there are close cross-border considerations. Might be worth building in some safeguards to give a balance of influence to the County. However, influence of the two cities is acceptable, provided that shortfalls in their own areas have not been instrumental in triggering the reserve release.

The three strategic planning authorities are jointly responsible for the Structure Plan. This is a matter of law; the balance of power between the County and City councils in this regard, cannot be altered.

35

All local authorities should have a reserve provision identified within their Local Plan that is capable of being brought forward without delay, should the need arise. There should be a single release to cover a 5-10 year period and not a piecemeal annual tinkering.

This is not a matter for the addendum to SPG on implementing policy H4.

38

Attention needs to be given to the mechanisms for releasing reserve sites in each district to ensure that the sites can be developed in the time required. Some districts have not allocated either some or all of their reserve site requirement. This means a lengthy consultation process in agreeing which sites should be developed. Where full provision has been made for reserve sites, no indication has been given to which sites would be developed first leading to further debate about which sites should be released, prolonging the development process. At the very worst it could mean planning by appeal in Hampshire.

See response to other comments in Appendix 1. It is a matter for the District Council to decide which site(s) to release, once a quantum of its reserve provision has been signalled for release by the strategic planning authorities.

39

Major Greenfield sites with considerable infrastructure implications are not being programmed for release because of the H4 approach, such that if they were needed it would be too late to progress their release and deliver housing completions in place of a site that has itself failed to deliver.

See response to other comments in Appendix 1.

18, 32

SPG is entirely unacceptable, it should not be progressed further.

See response to other comments in Appendix 1.

39

The system is unable to identify the appropriate site/sites to be released should a shortfall be identified, with adequate time to enable the site/sites to be promoted through the planning system and put into development. The alternative of anticipating an "impending failure" is a difficult concept, but would be needed if releases are to be triggered in sufficient time to fill the void.

Suggest a system of `start dates' be given to every major site for each stage of its local plan, outline, reserved matters, infrastructure and commencement of dwelling stages. Subsequently, if the site misses any trigger dates it would be much easier to assess whether the site will be unable to deliver the assumed number of dwellings in the Structure Plan period, and will trigger a compulsory release of reserve land.

See response to other comments in Appendix 1.

Your suggested system of start dates will be given further consideration.

2

The report is `gobblegook'. There needs to be more brevity.

See response to question 1 in Appendix 1.

4, 11, 26

No comments to make on draft addendum.

Noted.