Archived decisions

STRATEGIC PLANNING JOINT ADVISORY PANEL

Date: 10 March 2004 Item 5

Report by: Hampshire Director of Environment, Portsmouth City Planning
Officer and Southampton Executive Director of Development and Sustainability

    Policy H4 Monitoring Paper 2004 - Overall Consultation Response

Written by: Sue Clark, tel 01962 845890 email: [email protected]

Purpose and Summary:

To inform the Panel of the conclusions arising from the Hampshire County Structure Plan Policy H4 Monitoring Paper 2004 and the outcome of consultation.

The Paper concludes that the forecast dwelling supply 2003-2011 exceeds the requirement in Regional Planning Guidance (RPG). Taking the supply figures at face value, there is, therefore, no compelling justification at this time to release any of the Structure Plan housing reserve. However, this does not mean that the reserve will not be needed at all in the period to 2011. There is some uncertainty regarding the supply figures, particularly in relation to the likely contribution from Major Development Areas (MDAs) and urban capacity. There is also the possibility that the housing requirement in the South East Plan, when developed, will be higher than current RPG.

A total of 38 organisations and individuals commented on the Monitoring Paper. The Government Office for the South East (GOSE) consider that the short term position appears sound, but it is concerned over the accuracy of the long term forecasts. GOSE asks that this Panel considers the release of at least some of the reserve in order to provide certainty that housing numbers will be met. The development industry considers that the Paper is overly optimistic and calls for an immediate release of reserve provision. Other consultees have tended to back the overall findings of the Paper.

Despite the misgivings of some respondents, the overall conclusion of the Paper - that there will be sufficient supply to meet requirements to 2011 - is considered to be a fair assessment based on current information. There is currently no "compelling justification" (the test set in the Structure Plan Policy H4) to justify the release of any of the reserve provision. However, if there are further delays in bringing forward some of the large sites and MDAs or if completions are not as high as predicted, next year's Paper may reach a different conclusion.

A separate report considers the GOSE representations in detail. It also reports on a request to the leaders of the three strategic planning authorities from the Planning Minister, Keith Hill MP, to release the reserve provision.

RECOMMENDATION:

That the three Strategic Planning Authorities be recommended to:

    (i) note the consultation responses;

      (ii) agree no reserve sites be released at the present time, subject to the Panel's views on the request from the Government to release the reserve provision (dealt with in a separate report on the agenda),

      (iii) urge all local planning authorities to take proactive steps to manage housing land supply to meet or exceed their Structure Plan baseline housing requirement and make provision for the reserve provision, where required;

      (iv) agree that a report should be brought to the next meeting of this Panel on the actions being undertaken by local planning authorities to ensure that the predicted housing supply is forthcoming; and

      (v) thank all consultees who responded to this year's Monitoring Paper for their comments, enclosing a copy of this report and appendix and informing them of the decisions made by this Panel in respect of it.

1. Introduction

1.1 Policy H4 in the adopted Structure Plan provides a reserve of land for house building that will be released if, and when, the strategic and local planning authorities decide it is needed. The purpose of the policy is to ensure that sufficient housing land is provided throughout the Structure Plan area to meet identified needs, while avoiding the unnecessary use of greenfield land. This is a process for managing the supply of land for housing, including speedy decisions in response to monitoring. It represents the `monitor and manage' elements of the Government's 'plan, monitor and manage' approach to providing land for new housing.

1.2 Structure Plan policy H4 states that "The strategic planning authorities will only support the release of individual greenfield allocations to meet this reserve provision where monitoring of the Structure Plan and Local Plans indicates there is a compelling justification to do so." Policy H4 is in line with government guidance in PPG3 to give priority to re-using previously developed land within existing urban areas in preference to the development of greenfield sites.

1.3 Supplementary Planning Guidance (SPG) called 'Implementing Policy H4' was published by the three strategic authorities in June 2001 and explained how Policy H4 would be implemented. A draft addendum to the SPG, adding further clarification of the process of deciding where the release will be made, has recently been the subject of consultation. It is expected that the definitive version of the addendum will have been agreed by the Strategic Planning Authorities prior to this meeting. The cornerstone in the process is the publication of an annual monitoring paper.

1.4 The first two Policy H4 Monitoring Papers concluded that there was no case at that time for triggering the release of any of the reserve provision, but that the situation needed to be considered again when better information was available.

1.5 The Policy H4 Monitoring Paper 2004 was published in December 2003 and is based on completions information up to March 2003 and the most up-to-date estimates of future housing supply.

2. Aims and Visions of Corporate and Community Strategies

2.1 This report supports the aims and visions of the three strategic planning authorities' corporate and community strategies by helping ensure that sufficient new homes are made available whilst securing the regeneration of existing urban areas and avoiding the unnecessary development on greenfield land.

3. The 2004 Monitoring Paper

3.1 The 2004 Monitoring Reports forecasts that housebuilding 2001-2006 will exceed the RPG figure. Dwellings supply for the period 2006-2011 is also forecast to exceed the RPG figure.

3.2 The number of dwellings with planning consent is 8% up on the position in March 2002. There was full planning permission for over 13,300 dwellings in March 2003.

3.3 Taking the supply figures at face value indicates there is no requirement at this time to release any of the Structure Plan housing reserve.

3.4 Respondents to last year's monitoring paper requested that the estimated supply be adjusted to recognise that not all the dwellings that could be built by 2011 are likely to be built. This was undertaken and appears in the appendix to this year's Monitoring Paper. The adjustment is between 5% and 20% depending on the type of supply. The forecast of completions based on the adjusted supply indicates that housebuilding in 2003/04 is expected to exceed the RPG figure and to remain above the RPG for a further five years.

4. Consultation

4.1 The Monitoring Paper was sent to the 75 consultees who commented on previous years' Monitoring Papers, these representing a wide variety of interests (eg developers, local authorities, parish councils and conservation groups). In addition, a letter announcing publication of the Monitoring Report was sent out to the 1,500 or so recipients of the 'Planning Hampshire's Future' newsletter mailing list which resulted in the report being requested and sent out to a further 400 consultees.

4.2 Comments were received from 38 respondents:

    (i) 19 developer interests;

    (ii) 4 environmental/conservation groups;

    (iii) all Hampshire District Councils except Hart, Havant and New Forest;

    (iv) 3 parish councils

    (v) GOSE; and

    (vi) 3 others.

4.3 Although the consultation this year was much wider, the number of responses was only slightly higher than last year (38 this year, 31 last year) and half the responses were again from developer interests. The effect of this is reflected in the nature of the comments made, as shown in the attached Summary of the main points arising from consultation responses (see attached appendix).

5. Main Points Arising from Comments

    Completions

5.1 Some respondents point out that despite the increase in housing completions, the figure is still below the RPG figure. They suggest that the completion figures in some of the tables are misleading as they do not compare performance with the RPG requirement.

5.2 Many of the respondents from the development industry suggested that the improvement in completions should be seen in the long term context, they suggest that a shortfall of dwellings has accumulated.

5.3 There was some concern that the continuing shortfalls in housing completions will perpetuate house price inflation and further widen the affordability gap in Hampshire.

    Officers' Response

5.4 It is recognised that since 2001 - the start year of the RPG - housebuilding has been below the RPG figure (currently 6,030 per annum) but this year it is estimated that completions will exceed that figure and a sustained period of completions in excess of the current RPG requirement will follow. The cumulative shortfall in dwellings (1,645) compared to RPG requirements will gradually be recouped. Even using the adjusted forecast (in Appendix 6 of the Monitoring Paper) completions would exceed the current RPG requirement by a total of over 2,000 over the whole period 2001 to 2011.

    Urban Capacity

5.5 Several respondents from the development industry and GOSE considered that there was an over reliance on urban capacity sites and windfalls which, they argued, are unreliable sources. It was stated that the report should not base the assumptions of supply on the findings of urban capacity studies as many of the studies included over optimistic assumptions in relation to windfalls and sites that have been committed but not developed for many years.

    Officers' Response

5.6 PPG3 states that windfall allowances should be made on the basis of examining past trends in windfalls coming forward for development and on the likely windfall potential as assessed in capacity studies. In 2002 the Strategic Planning Authorities examined the urban capacity undertaken by Hampshire local planning authorities and concluded that they provided an acceptable basis for assessing potential supply. It is agreed that contributions from large urban capacity and windfall sites are not subject to the same level of scrutiny and consideration as allocations and sites with planning permission. The figures in capacity studies are discounted to make allowances for non-implementation, but there remains a prospect that some dwellings may obtain planning permission during the plan period but not be developed until after it. In recognition of this, an adjustment of 15% was made to large urban capacity and windfall sites (see page 32 of Monitoring Paper).

    Major Development Areas

5.7 The general view from the development industry was that the Paper was still too optimistic about the date when the MDAs will contribute dwellings and, as a consequence, the supply from this source was too high. On the other hand, developers who are directly involved in the MDAs stated that the completion assumptions in the Paper are over-pessimistic.

5.8 There was also a view that because baseline and reserve MDAs are major greenfield sites that have long lead in times, sites should be released immediately in order to deliver completions before 2011.

    Officers' Response

5.9 It is recognised that there is still some uncertainty about when development will start in the MDAs and what building rates will be achieved. In recognition of this a 20% adjustment was made to this source of supply. (see page 32 of Monitoring Paper)

5.10 MDAs need long lead-in times and will need to be released well in advance of when they are required. The monitoring indicates that there is no compelling justification for the release of reserve sites at the present time. If it was decided that some of the reserve was required towards the end of the plan period, MDA reserve sites could be released in future years and still make a contribution to completions before 2011.

    Overall Supply

5.11 There was concern from several respondents, including the HBF and GOSE about the reliability of long term forecasts because of the lack of detail on the source of additional dwellings and the wide difference in the forecasts for 2006-2011 in the last three reports.

5.12 Many of the development interests comment on the reference in the Paper to the sustained period of building 8,000 dwellings per annum in the 1980s, suggesting that similar circumstances no longer apply. GOSE considers that the assumed rate of completions in Southampton and Portsmouth is extremely optimistic and doubts whether such rates could be maintained for eight years. They consider that an average of 825 dwellings per year in Southampton is a phenomenal rate of completions that is extremely unrealistic and that neither the Southampton Local Plan nor evidence submitted to the local plan inquiry support this high and sustained rate of housing. GOSE considers that the position in Portsmouth appears even more optimistic: an average of 856 per year, compared with the average over the last three years of 572.

5.13 GOSE is concerned over the accuracy of the long term forecasts and asks that this Panel considers the release of at least some of the reserve in order to provide certainty that housing numbers will be met.

    Officers' Response

5.14 A number of criticisms were made of the 2002 Monitoring Paper and the 2003 Paper sought to address these and present a more robust analysis of dwelling supply. This was the main reason for differences between these two forecasts. Since last year the total dwelling supply has increased by 1,800. The number of identified large sites has increased by over 2,200 dwellings. The total number of urban capacity and windfall sites has decreased by over 1,000. Most planning authorities reported a decline in estimates of supply from this source compared with last year; however following discussions with developers and other agencies Southampton and Portsmouth have become aware of additional supply from urban capacity and windfall sites which are likely to come forward before 2011 and these have been included in this years forecast. It is inevitable that long term forecasts are less reliable than short term forecasts, however many of the additional dwellings are on large identified sites, they are clearly identified and a phasing is shown on a summary schedule.

5.15 In recognition of the fact that not all the dwellings that could be developed by 2011 are likely to be built, an adjustment to the supply was made in Appendix 6 to the Monitoring Paper. Adjustments of between 5% and 20% were made depending upon the type of supply. Using the adjusted forecast, completions would exceed the current RPG requirement by over 2,000 dwellings over the whole period 2001 to 2011.

5.16 The GOSE representations are considered in detail in a separate report on the agenda.

    Other Matters

5.17 The responses raised a number of other detailed points. These and the officers' response to them are contained in the appendix.

6. Conclusions

6.1 Many of the comments about the Monitoring Paper are the same as those expressed in previous years.

6.2 There remains much scepticism amongst the development industry regarding the overall supply figures used, the accuracy of the forecasts and consequentially its conclusions. GOSE is also concerned over the accuracy of the long term forecasts and would like some of the reserve released in order to provide certainty that housing numbers will be met. Other interested parties such as local planning authorities and local interest groups were much more supportive of the Paper and its findings and most of them supported the general conclusions of the report .

6.3 Despite the misgivings of some respondents, the overall conclusion of the Paper - that there will be sufficient supply to meet requirements to 2011 - is considered to be a fair assessment based on current information. There is currently no "compelling justification" (the test set in the Structure Plan Policy H4) to justify the release of any reserve provision. However, if there are further delays in bringing forward some of the large sites and MDAs or if completions are not as high as predicted, next year's Paper may reach a different conclusion.

6.4 For these reasons local planning authorities should continue to identify the full reserve provision in their local plans, as required by the Structure Plan. In the last year the amount of reserve provision in local plans has increased to almost 9,000 dwellings, 64% of the total requirement. In April 2003 this Panel agreed that decisions on where to release the reserve, should the need arise, would not be influenced by whether local planning authorities had identified it in their local plans.

6.5 The Government is looking for an increase in-house completions and proposes to intervene in areas which are not meeting their housing requirements. Most planning authorities in Hampshire are rising to the challenge - good progress is being made on local plan production; urban capacity studies have been produced for the whole of the county and progress on the MDAs (with the notable exception of Eastleigh) continues and the number of planning permissions granted is rising. Some planning authorities are now actively managing their land to increase the rate of development.

6.6 One area that is still not showing sufficient progress is the identification of the reserve provision. There are good reasons why, notwithstanding the conclusion in this Paper, the reserve may still be required in the future. The reserve provision may be necessary for the county to meet its RPG target, and all planning authorities should be concerned that it is not currently being fully planned.

6.7 If all parts of Hampshire had delivered at least their pro-rata baseline housing policy figure in 2002-03, the surplus generated by some would have ensured the structure plan area total met the RPG target. Local planning authorities should, accordingly, be urged to take proactive steps to manage housing land supply to meet their Structure Plan baseline housing requirement and make provision for the reserve provision, where required.

6.8 There are a number of greenfield sites around the county which form part of the baseline allocation in local plans, but are not currently identified as part of the supply to 2011. This is because they are being held back under `plan, monitor, manage'. These sites could be released prior to reserve sites if it was considered that there is a need for additional greenfield releases.

6.9 Local planning authorities should take action to ensure that the predicted housing supply comes forward by:

    (i) monitoring urban capacity sites on an annual basis;

      (ii) undertaking proactive work, including talking to landowners and developers and preparing development briefs for large sites;

    (iii) discussing with GOSE the need to fast track some of the baseline sites;

    (iv) ensuring that their local plan timetable does not slip; and

      (v) providing planning departments with sufficient resources to bring forward the housing supply as soon as possible.

Section 100 D - Local Government Act 1972 - background papers

The following documents disclose facts or matters on which this report, or an important part of it, is based and has been relied upon to a material extent in the preparation of this report.

NB the list excludes:

1.

Published works.

2.

Documents which disclose exempt or confidential information as defined in the Act.

TITLE

LOCATION

Project Plan for the South East England Regional Spatial Strategy

http://www.southeast-ra.gov.uk/regional_policies/planning/rss/index. html

8617/SC

APPENDIX

Summary of Main Points Arising from Consultation

List of Respondents

    1. Winchester City Council

    2. Old Basing Parish Council

    3. City of Winchester Trust

    4. David Pantling Consultancy - on behalf of George Wimpey Strategic Land

    5. John Hayter

    6. Rushmoor Borough Council

    7. Gosport Borough Council

    8. Boyer Planning on behalf of Grainger Trust Plc

    9. Boyer Planning

    10. Eastleigh Borough Council

    11. The Fareham Society

    12. East Hampshire District Council

    13. Adams Hendry on behalf of Bovis Homes

    14. Test Valley Borough Council

    15. Fareham Borough Council

    16. House Builders Federation

    17. Hythe and Dibden Parish Council

    18. Mr R. Howard

    19. Mason Richards Planning on behalf of Wates Landmark

    20. Terence O'Rourke on behalf of Taylor Woodrow

    21. Romsey & District Society

    22. Barton Willmore on behalf of Luckmore Ltd and Westbury Homes (Holdings) Ltd

    23. Sigma Planning Services on behalf of Rydon Homes Ltd

    24. Mason Richards Planning on behalf of CALA Homes (South)

    25. Chancellors (submitted on behalf of a number of house builder clients - not named)

    26. Terence O'Rourke Ltd on behalf of Hedge End North Consortium

    27. Government Office for the South East

    28. Abbotswood Consortium

    29. Charles Planning Associates on behalf of Bewley Homes PLC

    30. Broadway Malyan Ltd on behalf of Persimmon Homes (South Coast)

    31. Basingstoke & Deane Borough Council

    32. Highways Agency

    33. Campaign to Protect Rural England

    34. Berkley Community Villages

    35. Mrs P. Baker

    36. Froyle Parish Council

    37. Phillips Planning Services Ltd

    38. Environment Agency

NB: The number reflects the dates of receipt of the comments

Completions

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

13,16,25,27, 28,30

Report fails to clarify the source of the additional dwellings to be completed each year or to describe how circumstances have changed to deliver these additional dwellings. It is not satisfactory to simply make the assertion that all local planning authorities expect to meet baseline requirements by 2011, relying on districts own opinions on whether they will meet these targets.

See response in paragraph 4.14 -4.15 of main report. The strategic planning authorities have not relied solely on the districts figures for housing supply.

20, 23,24, 27,28,29

Despite the improvement in housing completions on the previous year, the figure is still below the RPG annual average (which may be increased in the near future). There is concern about the emphasis of section 4.1 on the increase in completions which misses the key point about the underperformance compared to RPG figures.

Underperformance compared to RPG annual average is acknowledged. See response in 4.4 of this report.

13,16,19,20,

24,25,26,30

Improvement in housing completions on the previous year should be seen in the long term context. In the 4-5 years preceding 2001/2002 there was a consistent yearly decline in housing completions and since 1996 an estimated shortfall of approx. 7,000 dwellings has accumulated. Actual completions were short of projected yield and therefore this casts doubt on the future projections in the report.

GOSE has confirmed that there is no requirement to make up any shortfall prior to 2001. Estimations of completions in last year's report where within 3% of the number built in 2002/03.

16,22,27,28

Concern about the reliability of long term forecasts because to the lack of detail on the source of additional dwellings and the wide difference in the forecasts for 2006-2011 in the last 3 reports. This report estimates a substantial increase in annual completions rates compared to the last report.

See response in 4.14 of this report.

23,28

Overall improvement in completions masks significant variations between districts with numerous districts not managing to build the annualised requirement. Whilst overprovision in urban areas may not be inconsistent with national planning policy (although the implications of this should be considered), low output in north Hampshire, where research by Nathaniel Lichfield & Partners identified that 62% of the shortfall will occur, and overprovision in New Forest were not intended in the Structure Plan. Relying on certain districts exceeding annual requirement does not relieve the under-provision in other areas but merely results in shortages and imbalances between districts. The avoidance of this is a key reason for the existence of the Strategic Planning Authorities.

Agree that there are significant variations in completions between the districts. However almost all districts are projected to meet their baseline requirement by 2011.

16,19,20,24,

26

Shortfalls in the pre-2001 period should not be ignored.

GOSE has confirmed that there is no requirement to make up any shortfall prior to 2001.

5

The 97% accuracy of the forecast is nothing remarkable as this forecast was made only 6 months from year end with the completions being regularly monitored.

There is a gap in time between dwellings being completed and this information being received by the strategic authorities. The authorities were pleased with the accuracy of the forecast, but did not consider it remarkable.

28

The Strategic Planning Authorities cannot claim confidence in the forecasting process on the basis of a single years figures.

The accuracy of the forecast gives some confidence in the robustness of the forecasting process, however it is inevitable that forecasting for the next few years will be more accurate than that at the end of the Structure Plan period.

9,29

Long lead in time to deliver the housing necessitates positive intervention and the release of reserve land now.

See response in paragraph 4.10 of main report.

28

Fundamental question is not whether but when the reserve sites should be released. The use of the phrase `early release' is inappropriate in paragraph 4.1 as this implies a philosophy of constraint.

Policy H4 states that there should be a compelling justification for the reserve sites to be released.

16,23,25,27

Completion figures in tables 2 & 3 are misleading as they do not compare performance with the RPG requirement. Comments in paragraph 5.4 & 5.5 and the information within these tables are largely irrelevant.

Comparison with RPG figures is not possible when completions are examined at sub-area or district level.

13

The substantial shortfall which has accumulated since 2001 (13.6) is proportionally worse than the average for the whole GOSE region (11.6%).

This short fall is expected to be made up in the next few years. See response in paragraph 4.4.

5,19,24,34

Continuing shortfalls in housing completions will perpetuate house price inflation and further widen the affordability gap in Hampshire.

The shortfall in housing is a small percentage of the total housing available for sale; however it is important that completions are increased so that any impact on affordability or house price inflation is minimised.

Estimates of Housing Supply

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

20,25,26,30

Housing requirement of 94,290 dwellings should be the target, not just the baseline. Even if all authorities meet their baseline, there would be a shortfall compared to RPG.

The target is to meet the RPG figure. If all authorities built as a minimum their annualised baseline requirement, the additional dwellings in some areas would mean that the County as a whole would exceed the RPG figure.

13

Compared to the approaches adopted elsewhere in the region, Hampshire appears to be placing an unduly high reliance on unidentified sites to meet its housing requirement.

See response in paragraph 4.4 of main report.

16

Report assumes that every small site currently committed for development will be completed - past experience suggests that a large proportion of small site permissions are never implemented and a discount rate of up to 50% should be factored in.

A discount is applied to the supply in appendix six of the monitoring paper; however no discount is applied to small sites as the future supply of dwellings from small sites is based on trend analysis of the past five years actual rates of completions.

16

Housing supply calculations should not count sites as commitments if they do not have permission of any kind and are not allocated. HSPAs should set out how many of the dwellings are actually allocations.

The identified sites comprise those with planning permission, those which are committed as a result of appeal or committee decision and allocations, which are identified in an approved local plan or policy statement or in plans which have been placed `on deposit'. The number of dwellings committed as a result of appeal or committee decision is relatively small.

28

There is little about the broader social and economic factors including house price inflation, the need for affordable housing, labour demand and supply.

The purpose of the paper is to compare housing supply with policy requirements and conclude whether or not there is a need to release any of the reserve housing provision. If it was decided that a release was necessary, these factors would be amongst those considered when deciding where to make the release.

Urban Capacity

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

19,20,23,2427,28

There is an over-reliance on unidentified sources, namely urban capacity sites and windfalls which are unreliable.

See response in paragraph 4.6 of main report.

19,20,23,2627,28

Report should not base the assumptions of supply on the findings of Urban Capacity Studies as these sites are notoriously unreliable and very often severely constrained in their developability. Many include over-optimistic assumptions in relation to windfalls and include sites that have been committed but not developed for many years.

See response in paragraph 4.6 of main report.

13,28

More evidence is required to demonstrate the contribution from urban capacity sites.

Further work will be undertaken to assess urban housing potential following the recent guidance produced by Baker Associates on behalf of GOSE and SEERA.

33

The degree of rigour of the Urban Capacity Studies varies immensely between Local Planning Authorities

See comment above

15

Support review of Urban Capacity Studies in the light of forthcoming guidance.

Noted. See comment above

20,26

Report include assumptions that the economy will remain buoyant, however land is becoming scarcer in urban areas and housebuilders/ landlords ability to develop small urban sites tend to be more vulnerable to regular fluctuations in the economy.

There is no evidence that the supply of sites in urban areas is becoming scarcer in the period up to 2011.

16

Merely establishing a consistent approach towards urban capacity is of little value if that consistent approach is flawed. There is a lack of detailed site analysis and contact with landowners and developers in the studies.

Further work will be undertaken to assess urban housing potential following the recent guidance produced by Baker Associates on behalf of GOSE and SEERA.

Major Development Areas

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

14

Andover MDA - recommend that the text be changed to indicate that 2,400 dwellings will be built by 2011.

It is not considered realistic, at this stage, to expect all 2,400 dwellings to be completed by 2011.

23,28

Basingstoke MDA - expected to deliver 4,000 dwellings by 2011, yet development is not expected to commence until 2005/06. It is unrealistic to assume high enough levels of completions can be sustained over such a long period.

The action plan for north Basingstoke will deliver the MDA requirement over a number of sites. The estimate of completion rates on these sites is considered realistic.

26,28

Eastleigh - H4 Monitoring Report should be used as a mechanism to provide a clear position on their omission of the MDA.

This is not considered appropriate.

4,8

West of Waterlooville MDA - completion assumptions are over-pessimistic. There is a strong probability that 2,000 completions will be achieved by 2011, through housebuilders and RSLs implementing the scheme simultaneously, even if site works do not begin until 2005/06.

It is not considered realistic, at this stage, to expect all 2,000 dwellings to be completed by 2011.

30

Recent performance does not support the principle of exceptionally high completions in Basingstoke, Andover or Waterlooville.

Once planning permission is granted for the large greenfield sites which comprise the MDA requirement in these areas and development is underway, completions will rise significantly.

16,23

There is an unrealistic over-reliance on MDAs to deliver housing numbers. Anticipated supply is optimistic due to the Local Plans treatment of MDA allocations, especially Eastleigh.

MDAs are part of the Structure Plan's strategy for housing provision; changing the amount provided by MDAs would necessitate changing the Structure Plan policy which can only be done by a formal review of the Plan. See response in paragraph 4.9 - 4.10 of main report.

13,34

The MDAs baseline and reserve elements are major Greenfield sites that have long lead in times, between 3-8 years from submission of outline application to start on site, plus another year to actual completions. Therefore to deliver these before the end of the plan period, sites should be released immediately.

See response in paragraph 4.9 - 4.10 of main report.

Overall Supply & Policy Requirements

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

27

Assumed rate of completions is extremely optimistic and suggested future average for Southampton have only been bettered by areas of growth on Greenfield sites, Portsmouth is even more optimistic. Doubtful whether such rates could be maintained for 8 years.

See separate report on GOSE representations.

5,13,16,19,

20,24,26,28

Reference to sustained rate of house building in the 1980s, however these circumstances no longer apply; characterised by the availability of Greenfield land with a significant contribution from public housing programmes. There has also been changes to the planning system since this time.

See response in paragraphs 4.14-4.15 of main report.

23

Developer's experience is that the housing market has been and continues to be buoyant through most of the County including under-performing districts. The lack of suitable housing sites is the only plausible reason for under-performance in a buoyant market.

More housing sites will come forward as part of the local plan process. Local authorities should consider whether it would be appropriate to fast-track any sites.

15

Progress on local plans and increased supply with planning permission should increase completions and ensure RPG figures are met.

Agree.

Overall Conclusions

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

1,3,11,12, 14,15,17,18,

21,32

Broadly support general conclusions of the Report.

Noted.

27

Disagrees with recommendations and therefore JAP is asked to consider the release of at least some of the reserve.

It is not considered necessary to release any reserve this year.

30,34

Conclusions are disappointing following the former Planning Minister's submission in 2003 and Government statements.

Views are noted

16

HBF is actively seeking Ministerial intervention to force the HSPAs to sanction the release of reserve sites.

Leaders of the Strategic Planning Authorities are meeting the minister prior to this meeting.

1,12,15

Support the need for each authority to make full provision for their reserve housing sites and that future releases will not take into account whether the district has identified reserve provision in their Local Plan.

Noted.

3,10

Suggests that the tables in the report provide separate statistics for the parts of districts divided between sub-divisions of the Structure Plan.

Will consider whether this can be done for any of the statistics in next year's monitoring paper.

35

Contest the need to build additional dwellings at such speed - priority should be given to local people and we should not be encouraging people to move to Hampshire.

It is necessary to meet the RPG housing requirement.

Other Matters Raised

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

19,22,24,29

Supports HBF comments.

Noted.

16

Many of the concerns expressed are the same as those raised in 2002 and 2003.

Noted.

5,13,14,19,

24,28,31

Queries about the detailed figures, discount rates and trends in the report.

The total supply figure in the Monitoring Paper represents the optimum that could be realistically achieved. The figures were produced by the planning authorities, although house builders were invited to submit their estimates of future completions on sites in their ownership to help improve the knowledge base. The adjustments applied to the total supply seem reasonable and reflect the differences in the sources of supply. The trends in the Paper reflect the view that the overall potential supply has increased in the past year.

3

Should be made clear if unanimity on a release is required from all 3 strategic planning authorities or simply a majority.

The Strategic Planning Authorities will reach a decision having regard to the recommendations of the Joint Advisory Panel.

1

Emphasising that releases would only normally be done where there is a shortfall in the district concerned.

Releases will be made in accordance with the approved SPG and may not necessarily be in those districts where there is a shortfall.

7

Draw JAPs attention to the continuing high level of housing completions in Gosport and the significant contribution to the Hampshire total.

Noted.

31

Aware that Basingstoke and Deane did not meet its baseline last year and has taken steps in conjunction with GOSE to improve its systems for monitoring housing delivery to increase delivery rates. Three large outline application forming North Popley development (+2,000 dwellings) will be reported to committee in March 2004.

Noted.

15

Fareham's reserve provision of 1,500 dwellings will be identified in the forthcoming LDF.

Noted.

32

Suggests consideration given to the availability of infrastructure - affecting delivery and lead time of the reserves.

Planning authorities have started addressing this as part of this years response to the Monitoring Paper. This will be reviewed and refined for next years Monitoring Paper.

3

Need to consider if it is necessary to identify important changes and developments more frequently than once a year - either semi-annually or quarterly.

Generally agree but this does raise resources issues - some planning authorities do have the resources to carry out more frequent monitoring but not all.

3,16

It would be helpful to have the annual housing land supply monitoring report published at the same time as the monitoring report.

It had been the intention to publish both documents at the same time but this did not prove possible.A summary schedule showing identified large site phasing was, however, made available to all who requested it via e-mail and this will be repeated next year.