Archived decisions

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

13,16,25,27,2830

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.

13,16,19,20,2425,26,30

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 have 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.

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.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

19,20,23,24,27,28

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.

19,20,23,26,27,28

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.

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.

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.

5,13,16,19,2024,26,28

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.

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.

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.

5,13,14,19,2428,31

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.